**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:**  **Safer Detergent Stewardship Initiative (SDSI) Program EPA ICR No.:**  **2261. 03**  **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 , 2 006 ) that announced the availability of the Final Aquatic Life Ambient Water Quality Criteria for Non ylphenol . Nonylphenol ethoxylates (NPEs ) and their breakdown products, such as non ylphenol, are toxic to aquatic life . SDS I will complement EPA’ s Aquatic L ife Criteria by

encouraging the manufacture and use of safer surfactants, thus reducing the amount of nonylphenol ethoxylate surfactants and nonylphenol in streams and other water bodies . The Design for the Environment (DfE) p rogram has identified safer al ternatives 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 surf

actants . Safer surfactants are surfactants that break down quickly to non - polluting compounds . Surfactants are used in a wide variety of applications and products . Examples include detergents, cleaners, airplane deicers, and fire - fighting foams . SDSI i s de signed 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 level, the participant is listed on the EPA SDSI website as a Champion and may use a special logo in their l iterature to help explain their participation in the program . The Partner category provides recognition of significant 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 available to EPA for review to verify that Champion status respondents have not taken action that would disqualif y them from continued recognitio n and use of EPA’s SDSI logo in product literature . For example, i n confirming continued eligibility for a formulating company , EPA would look to review information such as production - related records (which are already required b y EPA) toensure that the c ompan y used only safer surfactants (i.e., surfactants that break down quickl y to non - polluting comp o unds ) in its products. Candidates post a statement on their website describing the actions that qualify them for recognition under SDSI . Candidates also co mplete an application that describe s the actions t aken to qualify for recognition and have it signed b y 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 compan y or companies that operate outstanding or innovative source reduction programs . EPA developed SDSI i n recogniti on of th e s e directive s and through consultation with a broad range of stakeholders . SDSI ’s information collection 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 b y providing the means to , and an objective measure of , environmental stewardship. Investment anal ys ts and advisers seek these ty pes of meas ures in evaluating a corporation’s sustainability profile and investment worthines s. 1 SDSIis also needed to promote greater use of safer surfactants b y companies unaware of the benefits of such a change . EPA has carefull y tailored its request for informat ion, and esp eciall y the SDSI Application 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 SDSIApplication 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 ) determine 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 benefits, EPA will use its own Chemical Data Reporting Rule 2 to establish a baseline and track changes in

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 University Press, New Haven, CT; 2006 2 The Chemica l Data Reporting (CDR) Rule 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 athe 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 has not yet evaluated whether there is a correlation between SDSI participation and environmental outcomes, EPA remains committed to measuring the effec tiveness of this program over the next three years . **3 .**  **NON -**  **DUPLICATION, CONS 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 deve loping the program , EPA also checked with trade associations and potential partners to confirm that the information being collected by 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 through 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 stakeholders . 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. On June 12, 2006, DfE held a public 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 s trong support for SDSI . S takeholders who spoke to express support for the program at the public meeting include : periodic basis. CDR reporting occurs every f our years. The CDR data for calendar year 2011 was recently released for public use in February 2013.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 Hopkins, 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 Chem ical A minority

of stakeholders, representing 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 . Thei r concerns are summarized in the June 12 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 (no t 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 program 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 IC R 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 deve lopment of the renewal of this collection. **3(d) Effects of Less Frequent Collection**  The SDSIApplication Form is designed to be a one - time information submission for organizations that wish to participate in the SDSI p rogram as either a Partner or Champion . In 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 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.gov .**3(e) General Guidelines** 

The information collection activities discussed in this renewal ICR compl y 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 activit ies discussed in this document do not involve any sensitive questions. **4. THE RESPONDENTS AND THE INFORMATION REQUESTED**  **4(a) Respondents and NAICS Codes**  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 IC R . 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 will 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 Wholesalers 424990 Other Miscellaneous Nondurable Goods Merchant Wholesalers 4451 Grocery Stores 481 Air Transportation 561210 Facilities Support Services 561720 Janitorial Services 561740 Carpet and Upholstery Cleaning Services 611310 Colleges, Universities, 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 Form 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 literature. (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, re tail);  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 , showing one or more of the following (requirements vary by org anization 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 of senior company authority (e.g., CEO or vice president for h ealth 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;  Decide whether to appl y for recognition, and whether to appl y for partner or champion status;  Select a primary

contact person 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 complete d 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 foll owing 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 posed 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 applicants of the decisions. EPA is committed to evaluating whether there is a correlation between SDSIparticipation and environmental outcomes by using Chemical Data Reporting Rule data to establish a baseline and track changes in the levels of nonylphenol ethoxylate manufactured, imported and used in the U.S . EP A 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 l evels 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 thereb y confirming that their subsequent surfactant uses have not disqualified them from continued recognition and use of EPA’s SDSIlogo in product literature. **5(b) Collection 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 to 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 in the SDSI program will be small entities. EPA has designed its application form to minimize respondent burden while obtaining sufficientand accurate information . Inaddition, given the voluntary nature of the co llection, EPA expects that respondents will 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 P artners 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 designed 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: che mical manufacturers, formulators, retailers / distributors, institutional purchasers, and “ others. ” Among these participant categories , it is expected that the chemical manufacturers, formulators, retailers / distributors, and institutional purchasers wil l be private sector institutions . Within the participant category “others,” 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 estimate 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 pos ting information on a compan y website will take 1 hour (1 technical) . 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 o f 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) Estimating Respondent Costs** 

EPA estimates an average loaded hourl y labor rate (base hourly rate plus fringe and overhead) of $73 for managerial staff, $65 for technical staff, and $30 for clerical staff. These three labor rate estimates are based upon manufacturing industry wage dat a from the Bureau of Labor Statistics (BLS) Employer Costs for Employee Compensation, Supplementary Tables from March 2013 5 and are presented in Exhibit 6.2 of the supporting statement . The hourl y labor rates include a 17% overhead; this overhead rate is used for consistency with OPPT economic anal ys es for two major rulemakings: Wage Rates for Economic Analyses of the Toxics Release Inventory Program 6 and the Revised Economic Analysis for the Amended Inventory Update Rule: Final Report . 7 Inaddition, the hourly labor rates have been rounded for the purposes of this I CR. The ty pe of staff needed to complete the SDSI Application Form and their associated hourl y labor rates were verified during the original information collection approved b y OMB by contacting representatives from the participant categories. It is expected that these estimates will remain the same for this renewal. **6(c) Estimating the Respondent Universe and Total Burden and Costs Burden**  EPA estimates that 42 applications w ill be submitted over the three - ye ar life of the clearance . This estimate is based on the actual 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 (o r 42 applications) over the three - ye ar cycle of this I CR , based on the assumption that many companies 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 met the criteria for Champion or Partner . Furthermore, based on past experience with SDSI , EPA estimates that the vast majority

of participating companies will be fo rmulators, along with a small number of chemical manufacturers, retailers / distributors, institutional 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 $ 24,696 , respectivel y (see Exhibit 6.1) . The annual burden and cost, therefore, are 140 hours and $ 8,232 . This I CR does not impose capital or O&M costs. **6(d) Estimating Agency Burden and Costs**  Exhibit 6. 3 prese nts 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 experienc e managing this information collection and other voluntary programs.

5 BLS, 2013. Employer Costs for Employee Compensation

– December 2006
-March 2013, "Table 2: Private Manufacturing Industry Workers, by occupational group, employer costs per hours worked for employee compensation and costs as a percentage of total compensation" . Available at http://www.bls.gov/ncs/ect/sp/ecsuph st.pdf . 6 EPA, 2002. U.S. EPA, Office of Pollution Prevention and Toxics, Economic and Policy Analysis Branch, Wage Rates for Economic Analysis of the Toxics Release Inventory Program. Washington, DC: June 10, 2002. 7 EPA, 2002. U.S. EPA, Office of Polluti on Prevention and Toxics, Economic and Policy Analysis Branch. Revised Economic Analysis for the Amended Inventory Update Rule: Final Report. Washington, DC. August 2002.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 $ 77 for managerial staff, $ 57 for technical staff, and $ 26 for clerical staff. 8 The Agency expects most activities to be performed b y managerial staff (25 percent) and technical staff (75 percent).

8 EPA labor costs are based on annual federal wage rates published by the Office of P ersonnel Management for the 2013 General Schedule (Base) Pay Tables . These three labor rates were estimated using the following GS - levels: GS - 13 Step - 5 for managerial staff ($48.35/hour), GS - 10 Step - 10 for technical staff ($35.42/hour), and GS - 5 Step - 1 fo r clerical staff ($16.33/hour). http://www.opm.gov/policy - data - oversight/pay - leave/salaries - wages/2013/general schedule/dcb_h.pdf**Exhibit 6.1 .**  **Estimated Burden and Costs to Res pondents**  **9 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 C** **P r** **i v** **a t** **e S** **e c** **t o** **r Che**  **mi cal Manufacturers**  1  Review application and program information 0 1 0 0 1 0 1 $73 $65 $30 $65  Obtain senior approval 1 1 1 1 1 1 3 $73 $65 $30 $168  Complete and submit package 10 0 4 1 0 4 1 5 $73 $65 $30 $290  Post information on website 0 1 0 0 1 0 1 $73 $65 $30 $65 **Subtotal 1**  **1 7**  **2 1**  **7 2**  **10** -- -- -- **$588 Formulators**  32  Review application and program information 0 1 0 0 32 0 32 $73 $65 $30 $2,080  Obtain senior approval 1 1 1 32 32 32 96 $73 $65 $30 $5,376  Complete and submit package 6 0 4 1 0 128 32 160 $73 $65 $30 $9,280  Post information on website 0 1 0 0 32 0 32 $73 $65 $30 $2,080 **Subtotal 32**  **1 7**  **2 32**  **224 64**  **320** -- -- -- **$18,816 Institutional Purchasers**  4  Review application and program information 0 1 0 0 4 0 4 $73 $65 $30 $260  Obtain senior approval 1 1 1 4 4 4 12 $73 $65 $30 $672  Complete and submit package 6 0 4 1 0 16 4 20 $73 $65 $30 $1,160  Post information on website 0 1 0 0 4 0 4 $73 $65 $30 $260 **Subtotal 4**  **1 7**  **2 4**  **28 8**  **40** -- -- -- **$2,352 Retailers/Distributors**  1  Review application and program information 0 1 0 0 1 0 1 $73 $65 $30 $65  Obtain senior approval 1 1 1 1 1 1 3 $73 $65 $30 $168  Complete and submit package 6 0 4 1 0 4 1 5 $73 $65 $30 $290  Post information on website 0 1 0 0 1 0 1 $73 $65 $30 $65 **Subtotal 1**  **1 7**  **2 1**  **7 2**  **10** -- -- -- **$588 P** **r i** **v a** **t e** **S e** **c t** **o r** **a n** **d L** **o c** **a l** **G o** **v e** **r n** **m e** **n t**  **Others (e.g. non -**  **profits, unions, academ ia)**  4  Review application and program information 0 1 0 0 4 0 4 $73 $65 $30 $260  Obtain senior approval 1 1 1 4 4 4 12 $73 $65 $30 $672  Complete and submit package 6 0 4 1 0 16 4 20 $73 $65 $30 $1,160  Post information on website 0 1 0 0 4 0 4 $73 $65 $30 $260 **Subtotal 4**  **1 7**  **2 4**  **28 8**  **40** -- -- -- **$2,352 Total**  **(3 years) 42**  **420 $24,696** 
9 This ICR does not impose capital or OEM costs. 10 Includes burden of verifying data (about 8 hours), w hich 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 partic ipants) / 42 total participants).**Exhibit 6.2 .**  **Derivation of Respondent Loaded Labor 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 industries** , “Mgt, Business, and Financial” $44.24 $21.62 48.87% 17.00% 1.659 $73.38 **Professional/ Technical**  BLS ECEC, Private

**Manufacturing industries** , “Professional and related” $38.94 $19.58 50.28% 17.00% 1.673 $65.14 **Clerical** BLS ECEC, Private

**Manufacturing industries** , “Office and Administrative Support” $17.82 $8.97 50.34% 17.00% 1.673 $29.82 **Notes:** a (BLS, 201 3 ). http://www.bls.gov/ncs/ect/sp/ecsuphst.pdf . Bureau of Labor Statistics, Employer Costs for Employee Compensation

– December 2006
- March 2013 , "Table 2: Private Manufacturing Industry Workers, by occupational group, em ployer costs per hours worked for employ ee 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 and the Revised Economic Analysis for the Amended Invento ry Update Rule: Final Report . **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 $77 $57 $539 $1,311 30 $1,850 Answer questions 7 23 $77 $57 $539 $1,311 30 $1,850 Record / enter forms 10 30 $77 $57 $770 $1,710 40 $2,480 Verify information; Make awards selection 12 38 $77 $57 $924 $2,166 50 $3,090 Notify applicants of decision 3 9 $77 $57 $231 $513 12 $744 Total **39 123**  **-- --**  **$3,003 $7,011**  **162 $10,014**  a As seen in footnote 8 , 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**  **. Estimated**  **Total Respondent Burden and Cost Summary**  **Total Number of Respondents**  **Total Burden Hours**  **Total Labor**  **Cost**

42 (3 years) 420 (3 years) $ 24,696 a (3 years) 14 (annual) 140 (annual) $ 8,232 (annual) a This ICR incurs no capital or OEM costs.b. Agency Tall y **Exhibit 6. 5**  **. Average Estimated Agency Burden and Cost Summary** 

**Burden Hours Total L**  **abor Cost**  162 $ 10,014 **6(f) Reasons for**  **Change in Burden** There is no change in respondent burden from the information collection most recentl y approved b y OMB. **6(g) Burden Statement**  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 is defined in 5 CFR 1320.3(b). An agency may not conduct or sponsor, and a person is not required to resp ond to, a collection of information unless it displays a currentl y valid OMB control number . The OMB control numbers for EPA's regulations are listed in 40 CFR part 9 and 48 CFR chapter 15. The Agency

has established a public docket for this I CR under Doc ket ID No. EPA - HQ OPPT - 2012 - 0917, 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 holiday s. 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 minimizi ng respondent burden, including the use of automated collection techniques. Submit your comments, referencing Docket ID No. EPA - HQ - OPPT - 2012 - 0917 and OMB Control No. 2070 - 0171, to (1) EPA online using www.regulations.gov (our preferred method), or b y mail to: Pollution Prevention and Toxics Docket, Environmental Protection Agency Docket Center (EPA/DC), Mailcode: 28221T, 1200 Pennsylvania Ave., N.W., Washington, DC 20460, and (2) OMB b y mail to: Office of Information and Regulatory Affairs, Office of Manag ement and Budget (OMB), Attention: Desk Officer for EPA, 725 17th Street, N.W., Washington, DC 20503.**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 - 201 2 - 0917 . 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

online at the US House of Representatives’ Office of the Law Revision Counsel’s U . S . Code website **Attachment B: EPA F**  **orm 6300 -**  **2** - **SDSI Application Form**