ICR SUPPORTING STATEMENT OUTLINE

Part A

1. Identification of the Information Collection

1(a) Title of the Information Collection

Confidential Financial Disclosure Form 3110.48 for Special Government Employees (SGE) 

Serving on Federal Advisory Committees at the Environmental Protection Agency

1(b) Short Characterization/Abstract

The purpose of this information collection request is to assist the United States 

Environmental Protection Agency (EPA or the Agency) in selecting Federal advisory committee 

members who will be appointed as Special Government Employees (SGEs), mostly to EPA’s 

scientific and technical committees. To select SGE members as efficiently and cost effectively

as possible, the Agency needs to evaluate potential conflicts of interest before a candidate is 

hired as an SGE and appointed as a member to a committee by EPA’s Administrator or Deputy 

Administrator. 

Agency officials developed the “Confidential Financial Disclosure Form for Special 

Government Employees Serving on Federal Advisory Committees at the U.S. Environmental 

Protection Agency,” also referred to as Form 3110-48, for a greater inclusion of information to 

discover any potential conflicts of interest as recommended by the Government Accountability

Office. 

2. Need for and use of the Collection

2(a) Need/Authority for the Collection

In June 2001, the Government Accountability Office (GAO) issued a report entitled 

“EPA’s Science Advisory Board Panels – Improved Policies and Procedures Needed to Ensure 

Independence and Balance.” GAO recommended that EPA develop policies and procedures that 

better identify and mitigate potential conflicts of interest and support the development of 

balanced panels. Recommendations included gathering the required conflict of interest 

information before a member is selected, specifically:

 Determine whether each panel will be reviewing a “particular matter” before 

selecting the panel in order to identify the financial conflict-of-interest 

requirements, if any, to which the panelists will be subject.

 Obtain and evaluate relevant background information on peer review panel 

candidates before appointing panel members. The evaluation should include 

explicitly discussing with potential panelists: (1) items not adequately reported on 

the confidential financial disclosure form as well as items reported that could 

present conflicts of interest; (2) other information relevant to assessing 

impartiality, such as research conducted and previous public statements or 

positions on the matter being reviewed, interest of the employer or clients in the 

matter, participation in legal proceedings, work for chemical companies or other 

affected industries, and prior or current research grants that could be affected by
the matter; and (3) whether they have any potential conflicts of interest related to 

the specific panel being established. Further, pertinent information obtained from 

discussions with panelists should be documented.” 

As part of that effort to respond to GAO’s recommendations, EPA developed a new and 

improved form for all of its scientific and technical committee’s Special Government 

Employees. 

EPA’s Designated Federal Officers (DFOs) who manage EPA Federal Advisory

Committees (FACs) experienced great difficulty trying to use the OGE Form 450 to identify

actual or potential conflicts of interest of potential candidates for Federal Advisory Committee 

membership. The OGE Form 450 was confusing for the proposed members and they did not 

identify all financial interests of possible concern. In response to the GAO’s recommendations, 

EPA developed the Form 3110-48 to ensure that all relevant financial interests are identified and 

considered during the member selection process. It is important for EPA to have this 

information collection in place because we continuously need to appoint new SGE members as 

new advisory committees are created or as members’ terms of appointment expire. 

The Form 3110-48 is completed by candidates for membership as SGEs on EPA federal 

advisory committees. The form is completed as part of the member selection process and before 

they are invited to serve as a member of a FAC at EPA. The Form 3110-48 is reviewed by the 

Committee’s Designated Federal Officer, and the Program Office Deputy Ethics Official (DEO)

to determine whether there is a financial conflict of interest between the proposed member’s 

public responsibilities and private interests/activities and whether there is any appearance of a 

lack of impartiality. In some cases, the Alternate Designated Agency Ethics Official also 

reviews the form. As GAO recommended, it is important to collect this information before the 

potential member is appointed to the advisory committee, because if a conflict of interest is 

identified after the person is appointed, the Agency may have to terminate the person’s 

membership and identify another person to serve on the committee. This is potentially

embarrassing to both the Agency and the appointed member. It is also important to know upfront 

that a candidate could serve if appointed, as the appointment process is time consuming and, as 

required by the Federal Advisory Committee Act, the Agency must ensure that the advisory

committee is balanced in the points of view represented. If a conflict is identified after a person 

is appointed to an advisory committee as an SGE, additional time is needed to select a 

replacement and the Agency loses valuable time and expertise in receiving the advice it needs. 

Also important is the fact that finding replacement members creates a burden of additional cost 

and staff hours. Using the Form 3110-48 benefits EPA by increasing efficiency and saving time 

and money. 

Currently nine of EPA’s 22 Federal Advisory Committees (FACs) appoint members as 

SGEs and have need to use the Form 3110-48. This number may increase as new committees are 

added, or decrease as committees are terminated. EPA anticipates averaging approximately 257 

SGEs during the next 3 years.

Again, it is imperative that Form 3110-48 be approved to satisfy the GAO 

recommendations that EPA gather the required Conflict of Interest information before a member 

is selected to improve the EPA’s policies and procedures to better identify and mitigate potential 

conflicts of interest and support the development of balanced membership. EPA must have this 
information collection in place so that the EPA doesn’t lose continuity in appointing new Special 

Government (SGE) members, as new advisory committees are created, or as members’ terms of 

appointment expire. If a conflict is identified after an SGE is appointed to an advisory

committee, the SGE and the EPA face embarrassment and additional time is needed to select a 

replacement while EPA loses valuable time and expertise. Using the Form 3110-48 before 

member appointments are made benefits EPA by increasing efficiency, thus saving time and 

money. 

Confidentiality of Information provided on the Form 3110-48: 

Title I of the Ethics in Government Act of 1978 (the Act), 5 USC App., Executive Order 

12674, and 5 CFR Part 2634, Subpart I, of the Office of Government Ethics regulations require 

the reporting of financial information that is relevant to the administration and application of the 

criminal financial conflict of interest laws, administrative standards of conduct, and agencyspecific statutory and program-related restrictions. The primary use of the information collected 

on this form is to allow EPA to conduct the conflicts reviews in accordance with applicable 

Federal laws and regulations. The information reported on the Form 3110-48 is “confidential” 

and required to be withheld from the public pursuant to Section 107(a) of the Act. Agency

personnel shall not publicly release the reports on the information contained therein except that 

disclosures may be pursuant to (1) a Federal, State or local law enforcement agency if the 

disclosing agency becomes aware of a violation or potential violation of law or regulation; (2) a 

court or party in a court or Federal administrative proceeding if the Government is a party or in 

order to comply with a judge-issued subpoena; (3) a source when necessary to obtain information 

relevant to a conflict of interest investigation or decision; (4) the National Archives and Records 

Administration or the General Services Administration in records management inspections; (5) 

the Office of Management and Budget during legislative coordination on private relief 

legislation; and (6) in response to a request for discovery or for the appearance of a witness in a 

judicial or administrative proceeding, if the information is relevant to the subject matter. The 

confidential report will not be disclosed to any requesting person unless authorized by law.

EPA requires SGEs who are new to a federal advisory committee to complete parts 2-9 of 

Form 3110-48 before participating in a Committee activity. Subsequently, SGEs must file 

reports annually to report on the previous calendar year. For these annual reports, the SGEs must 

complete parts 2-8. In addition, they must complete Part 1 (“Statement regarding any change 

since annual submission of the form”) and Part 9 (“Identification of any other information related 

to conflicts of interest or appearance of a lack of impartiality”) before participating in any new 

advisory activity. Filers must provide sufficient information about outside interests and activities 

so that EPA DFOs and ethics officials can make an informed judgment regarding any conflict of 

interest or appearance of lack of impartiality. EPA staff may contact proposed SGEs to obtain 

additional information if necessary to determine whether there is a conflict between an SGE’s 

public responsibilities and his /her or his/her spouse's private interests and activities.

EPA seeks to collect the information in “Attachment A,” which is the Confidential 

Financial Disclosure for Special Government Employees Serving on Federal Advisory

Committees at the U.S. Environmental Protection Agency (Form 3110-48). This information 

collection request will be needed on a continual basis.

Again, it is imperative that Form 3110-48 be approved to satisfy the GAO 

recommendations that EPA gather the required Conflict of Interest information before a member 
is selected to improve the EPA’s policies and procedures to better identify and mitigate potential 

conflicts of interest and support the development of balanced membership. EPA must have this 

information collection in place so that the EPA doesn’t lose continuity in appointing new Special 

Government (SGE) members, as new advisory committees are created, or as members’ terms of 

appointment expire. If a conflict is identified after an SGE is appointed to an advisory

committee, the SGE and the EPA face embarrassment and additional time is needed to select a 

replacement while EPA loses valuable time and expertise. Using the Form 3110-48 before 

member appointments benefits EPA by increasing efficiency, thus saving time and money. 

2(b) Practical Utility/Users of the Data

Information gathered from Form 3110-48 will continuously help EPA to evaluate 

relevant background information on Special Government Employee candidates before appointing 

members. By using the form, EPA DFOs are allowed to expedite the process of selecting viable 

candidates for membership on EPA’s federal advisory committees. 

3. Non duplication, Consultations, and Other Collection Criteria

3(a) Non duplication

Almost all information request from respondents under this ICR is personal in nature and, 

in most cases, is not available from other sources. 

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

On November 24, 2010 (75 FR 71687) EPA sought comments on this ICR pursuant to 5 

CFR 1320.8(d). EPA received no comments. A second comment will be opened for 30-days 

once this ICR is submitted to OMB. 

3(c) Consultations

In accordance with OMB’s Terms of Clearance on the previous approval of this ICR, 

EPA has reviewed the actual number of SGE confidential disclosure forms received over the last 

three years and consulted with various agency staff to determine trends in expected committee 

membership over the next three years. While committee membership can vary year to year, EPA 

anticipates that the number of SGEs completing the form during the period of this ICR will not 

vary significantly from the previous three-year average, which was 257 per year.

3(d) Effects of Less Frequent Collection

The form is required to be updated once a year. The form allows Government officials to 

determine whether there is a statutory conflict between Special Government Employees public 

responsibilities and private interests and activities, or the appearance of a lack of impartiality, as 

defined by federal regulation.

18 U.S.C. 208: “An employee is prohibited from participating personally and substantially in an

official capacity in any particular matter in which, to his knowledge, he or any person whose 

interests are imputed to him under this statute has a financial interest, if the particular matter will 

have a direct and predictable effect on that interest.” 

5 C.F.R. 2635.502: Appearance of lack of impartiality: “Where an employee knows that a 

particular matter involving specific parties is likely to have a direct and predictable effect on the 
financial interest of a member of his household, or knows that a person with whom he has a 

covered relationship is or represents a party to such matter, and where the person determines that 

the circumstances would cause a reasonable person with knowledge of the relevant facts to 

question his impartiality in the matter, the employee should not participate in the matter unless 

he has informed the agency designee of the appearance of a problem and received authorization 

from the agency designee". 

3(e) General Guidelines

This ICR complies with OMB’s general guidelines for the collection of information.

3(f) Confidentiality

Confidentiality of Information provided on the Form 3110-48: 

Title I of the Ethics in Government Act of 1978 (the Act), 5 USC App., Executive Order 

12674, and 5 CFR Part 2634, Subpart I, of the Office of Government Ethics regulations require 

the reporting of financial information that is relevant to the administration and application of the 

criminal financial conflict of interest laws, administrative standards of conduct, and agencyspecific statutory and program-related restrictions. The primary use of the information collected 

on this form is to allow EPA to conduct the conflicts reviews in accordance with applicable 

Federal laws and regulations. The information reported on the Form 3110-48 is “confidential” 

and required to be withheld from the public pursuant to Section 107(a) of the Act. Agency

personnel shall not publicly release the reports on the information contained therein except that 

disclosures may be pursuant to (1) a Federal, State or local law enforcement agency if the 

disclosing agency becomes aware of a violation or potential violation of law or regulation; (2) a 

court or party in a court or Federal administrative proceeding if the Government is a party or in 

order to comply with a judge-issued subpoena; (3) a source when necessary to obtain information 

relevant to a conflict of interest investigation or decision; (4) the National Archives and Records 

Administration or the General Services Administration in records management inspections; (5) 

the Office of Management and Budget during legislative coordination on private relief 

legislation; and (6) in response to a request for discovery or for the appearance of a witness in a 

judicial or administrative proceeding, if the information is relevant to the subject matter. The 

confidential report will not be disclosed to any requesting person unless authorized by law.

EPA requires SGEs who are new to a federal advisory committee to complete parts 2-9 of 

Form 3110-48 before participating in a Committee activity. Subsequently, SGEs must file 

reports annually to report on the previous calendar year. For these annual reports, the SGEs must 

complete parts 2-8. In addition, they must complete Part 1 (“Statement regarding any change 

since annual submission of the form”) and Part 9 (“Identification of any other information related 

to conflicts of interest or appearance of a lack of impartiality”) before participating in any new 

advisory activity. Filers must provide sufficient information about outside interests and activities 

so that EPA DFOs and ethics officials can make an informed judgment regarding any conflict of 

interest or appearance of lack of impartiality. EPA staff may contact proposed SGEs to obtain 

additional information if necessary to determine whether there is a conflict between an SGE’s 

public responsibilities and his /her or his/her spouse's private interests and activities.

EPA seeks to collect the information in “Attachment A,” which is the Confidential 

Financial Disclosure for Special Government Employees Serving on Federal Advisory
Committees at the U.S. Environmental Protection Agency (Form 3110-48). This information 

collection request will be needed on a continual basis.

Again, it is imperative that Form 3110-48 be approved to satisfy the GAO 

recommendations that EPA gather the required Conflict of Interest information before a member 

is selected to improve the EPA’s policies and procedures to better identify and mitigate potential 

conflicts of interest and support the development of balanced membership. EPA must have this 

information collection in place so that the EPA doesn’t lose continuity in appointing new Special 

Government (SGE) members, as new advisory committees are created, or as members’ terms of 

appointment expire. If a conflict is identified after an SGE is appointed to an advisory

committee, the SGE and the EPA face embarrassment and additional time is needed to select a 

replacement while EPA loses valuable time and expertise. Using the Form3110-48 before 

member appointments benefits EPA by increasing efficiency, thus saving time and money. 

3(g) Sensitive Questions

Title I of the Ethics in Government Act of 1978 (the Act), 5 USC App., Executive Order 

12674, and 5 CFR Part 2634, Subpart I, of the Office of Government Ethics regulations require 

the reporting of financial information that is relevant to the administration and application of the 

criminal financial conflict of interest laws, administrative standards of conduct, and agencyspecific statutory and program-related restrictions. The primary use of the information collected 

on this form is to allow EPA to conduct the conflicts reviews in accordance with applicable 

Federal laws and regulations. The information reported on the Form 3110-48 is “confidential”

and required to be withheld from the public pursuant to Section 107(a) of the Act. Agency

personnel shall not publicly release the reports on the information contained therein except that 

disclosures may be pursuant to (1) a Federal, State or local law enforcement agency if the 

disclosing agency becomes aware of a violation or potential violation of law or regulation; (2) a 

court or party in a court or Federal administrative proceeding if the Government is a party or in 

order to comply with a judge-issued subpoena; (3) a source when necessary to obtain information 

relevant to a conflict of interest investigation or decision; (4) the National Archives and Records 

Administration or the General Services Administration in records management inspections; (5) 

the Office of Management and Budget during legislative coordination on private relief 

legislation; and (6) in response to a request for discovery or for the appearance of a witness in a 

judicial or administrative proceeding, if the information is relevant to the subject matter. The 

confidential report will not be disclosed to any requesting person unless authorized by law.

4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

A Special Government Employee (SGE) is a person who is retained, designated, 

appointed, or employed to perform, with or without compensation, for a period not to exceed 130 

days during any period of 365 consecutive days, temporary duties for the Federal Government 

either on a full-time or intermittent basis. SGEs who provide advice to EPA are required to file 

the Form 3110-48 in lieu of the Office of Government Ethics Form 450 to disclose confidential 

financial information. Form 3110-48 has already been reviewed and approved for use by the 

Office of Government Ethics. 

4(b) Information Requested
(i) Data items, including record keeping requirements

The Agency will maintain records of the Form 3110-48. Designated Federal Officers from 

Offices sponsoring federal advisory committees will retain files of the completed form. The 

Agency does not anticipate any record keeping activities on the part of the respondents under this 

ICR. 

(ii) Respondent Activities

After being nominated by an outside party or themselves, respondents will be asked to 

Complete the Form 3110-48. Forms may be mailed or e-mailed to candidates. Although 

candidates may type their information on the form on-line, they must then print the form and 

sign it. They may return the form by mail, but may not return the form by e-mail as an original 

signature is required. Each form will involve reading instructions and completing the form. 

The form will require one hour to complete. Subsequent forms filed annually should take less 

time to complete as respondents gain familiarity with its information requirements and may only 

need to make slight changes to information filed previously.

5. The Information Collected–Agency Activities, Collection Methodology, 

and Information Management

5(a) Agency Activities

To respond to this ICR, we estimated that Designated Federal Officers (DFOs) spend one 

hour reviewing each Form 3110-48 (sometimes calling and asking for further clarification or to 

address areas not filled out completely). EPA currently pays an estimated labor cost of GS 14 

Step 10, which in 2011 was $65.53 per hour, rounded to $66 per hour according to the Office of 

Personnel Management (http://www.opm.gov/oca/11tables/html/dcb_h.asp). Due to the 2011 

federal employee pay freeze for the next 2 years and possibly beyond, we anticipate no cost 

increase for the next 3 years of this ICR (2011, 2012, 2013) the 3 year average estimated cost for 

the DFO is $16,962.

 The EPA Deputy Ethics Official (DEO) labor cost is estimated to be a GS-15 Step 7, 

which in EPA’s Emergency ICR (2010) was $71.16, rounded to $71 per hour at one hour per 

form. Due to the 2011 federal employee pay freeze for the next 2 years and possibly beyond, we 

anticipate no cost increase for the next 3 years of this ICR (2011, 2012, 2013) the 3 year average 

estimated cost for the DEO is $18,247. 

Both DFO and DEO total labor rates below include a factor of 1.6 (60%) for overhead costs.

DFO Cost

EPA estimates that approximately 257 advisory committee members will serve on EPA’s 

Federal Advisory Committees (FACs) as SGEs over the next 3 years. Multiplying the number 

of SGE members (257) by the 3 year average dollar amount paid to EPA’s DFOs ($66), and 

multiplying the subtotal cost of $16,962 by 1.6 (60% overhead) to allow for employee overhead 

costs, we estimate the subtotal to be $27,139. 

Year 1 @ $66 for 1 hour x 257 = $16,962 x 1.6 = $27,139
Year 2 @ $66 for 1 hour x 257 = $16,962 x 1.6 = $27,139

Year 3 @ $66 for 1 hour x 257 = $16,962 x 1.6 = $27,139

DEO Cost

Multiplying the number of SGE members (257) by the dollar amount paid to EPA’s DEO 

with a 3 year average cost ($71), and multiplying the cost of $18,247 by 1.6 (60% overhead) to 

allow for employee overhead costs, we estimate the subtotal to be $29,195. 

Year 1 @ $71 for 1 hour x 257 = $18,247 x 1.6 = $29,195

Year 2 @ $71 for 1 hour x 257 = $18,247 x 1.6 = $29,195

Year 3 @ $71 for 1 hour x 257 = $18,247 x 1.6 = $29,195

Total DFO and DEO Cost Using 3 Year Average

The total 3 year average dollar burden estimate for this ICR (for both DFOs and DEO) is 

approximately $56,334 each year.

DFO 3 year average $27,139 + DEO 3 year average $29,195 = $56,334

Agency (EPA) activities associated with the collection of information include:

 Designated Federal Officers (DFOs) for each committee with Special Government 

Employees (SGEs), Deputy Ethics Official, Assistant Deputy Ethics Official

 First internal EPA review and approval of Form 3110-48 (completed 2003)

 Second internal EPA review and approval of Form 3110-48 (completed 2007)

 Taking actions to review the form, ascertain improvements, and revise periodically

(approximately 3 year intervals or more if needed) 

Designated Federal Officers (DFOs) for each committee with Special Government Employees 

(SGEs):

 Providing copies of the mandatory form

 Answering any respondent questions, follow-up

 Gathering respondents completed forms

 Reviewing and analyzing data

 Recordkeeping/storing completed form

 Forwarding form to EPA’s Ethics staff for review and analyzing

Deputy Ethics Official:

 First review and approval of Form 3110-48 (completed 2003)

 Second review and approval of Form 3110-48 (completed 2007)

5(b) Collection Methodology and Management

In collecting and analyzing the information associated with this ICR, EPA will use a 

telephone system, personal computers, e-mail and websites from which the respondents can 

obtain blank forms, as well as using the mail and committee meetings for distribution of the 

form. Although candidates (respondents) may type their information on the form on-line, they

must then print the form and sign it. They may return the form by mail, but may not return the 

form by e-mail as an original signature is required. 
Although EPA uses internet websites and e-mail to distribute the blank forms, this form 

is not a survey instrument, and no database is necessary to aggregate results.

This information is not available to the public.

5(c) Small Entity Flexibility

Not applicable

5(d) Collection Schedule

 After being nominated by an outside party or themselves, respondents are asked to 

Complete the Form 3110-48 (No schedule – dates are variable). 

 After the initial completion of the Form 3110-48, respondents are asked to update the 

form annually (generally during January of each year). Respondent’s confidential 

financial information is not made public.

6. Estimating the Burden and Cost of the Collection

6(a) Estimating Respondent Burden and Costs

(i) Estimating Burden and Labor Costs

The respondents for this information collection request are candidates who are willing to 

serve on EPA Federal Advisory Committees as Special Government Employees (SGE). An SGE 

is a person who is retained, designated, appointed, or employed to perform, with or without 

compensation, for a period not to exceed 130 days during any period of 365 consecutive days, 

temporary duties for the Federal Government either on a full-time or intermittent basis. SGEs 

who are currently members of EPA advisory committees must file the Form 3110-48 once a 

year. In addition as new candidates who wish to be considered for such service must file before 

they are formally appointed by the EPA Administrator or Deputy Administrator. 

To respond to this ICR, we estimated that each responding SGE candidate will take one 

hour to complete the Form 3110-48. We anticipate that EPA will pay an estimated labor cost of 

$66, which including the standard overhead factor of 1.6 produces a loaded wage rate of 

$105.60. We estimate that approximately 257 members of Advisory Committees will have to 

respond to this request each year. Multiplying the estimated number of SGE members (257) by 

the dollar amounts to be paid to EPA’s SGEs each successive year, and multiplying the subtotal 

costs of each successive year by 1.6 to allow for respondent overhead costs, we estimate that the 

total dollar burden estimate for this ICR to be approximately $27,139 for year 1, $27,139 for 

year 2 and $27,139 for year 3. The grand total for all 3 years is estimated at $81,417. The 

annual average cost to all respondent’s cost over the three years is $27,139, as indicated in the 

following annual respondent burden and cost table.

Annual Cost for SGE Respondents 

SGE Respondent 

Activities to Complete 

Form 3110-48

Burden Hours/

Respondent

Burden for SGE 

Candidate

Number of 

Respondents 

per Year

Total

Cost per 

Year
($66 per labor 

hour multiplied 

by 1.6 for 

overhead equals 

$105.6)

Total per Year 60 minutes 

(1 hour/100%)

$105.6 257 $27,139

 Read Instructions 10 minutes

(~0.17%)

(0.17 x $105.6 =) 

$17.60

($17.95 x 257 =) $4,523.20

 Fill Out Form 48 minutes

(~0.80%

(0.80 x $105.6 =)

$84.48

($84.48 x 257 =) $21,711.36

 Prepare Envelope to Mail 2 minutes

(~0.03%)

(0.03 x $105.6 =)

$3.5

($3.17 x 257 =) $904.64

TOTAL 60 minutes $105.60 257 $27,139.20

(ii) Estimating Capital and Operations and Maintenance Costs

Not applicable.

(iii) Capital/Start-up Operating and Maintenance (O&M) Costs

Not applicable.

(iv) Annualizing Capital Costs

Not Applicable

6(b) Estimating Agency Burden and Cost

Annual Agency Burden and Cost

Agency

Hours 

Number 

of Hours 

Per Year

Labor Cost 

Per Year

Overhead 

Cost Per 

Year

Subtotal 

Labor & 

Overhead 

Cost 

Total

Cost/

Year

(rounded)

Form 3110-48

DFO Activities

For 257

Respondents

$66 per hour 

Distribute form 

to SGE 

Nominees 

(respondents) 

and answer their 

questions

5 minutes

(0.0833)

257 $1,413.50 $848.10 $2,261.60

Review and 

analyze data of 

45 minutes

(0.75)

257 $12,721.50 $7,632.90 $20,354.40
completed form, 

and ask followup questions

Recordkeeping/

storing form 

5 minutes

(0.0833)

257 $1,413.50 $848.10 $2,261.60

Forward form to 

EPA Ethics 

Staff

5 minutes

(0.0833

257 $1,413.50 $848.10 $2,261.60

 DFO 

Subtotal

60 min./1 hour

(1.00)

257 $16,962.00 $10,177.20 $27,139.20 $27,139

DEO Activities 

For 257

Respondents

$71 per hour 

Review, 

analyze, followup, and approve 

or disapprove

60 min./1 hour

(1.00)

257 $18,247.00 $10,948.20 $29,195.20

 DEO

Subtotal 

60 min./1 hour

(1.00)

257 $18,247 $10,948 $29,195 $29,195

EPA Grand 

Total

(DFO & DEO)

120 min./ 2 

hours

2.00

514 $35,209.00 $21,125.40 $56,334.40 $56,334

6(c) Bottom Line Burden Hours and Cost Tables

(i) Respondent Tally

Bottom-Line Annual Burden and Cost for SGE Respondents 

SGE Respondent 

Activities to Complete 

Form 3110-48

Burden Hours/

Respondent

Burden for SGE 

Candidate

($66 per labor 

hour multiplied by 

1.6 for overhead 

equals $105.6)

Number of 

Respondents 

per Year

Total

Cost per 

Year

Total per Year

60 minutes 

(1 hour/100%)

$105.6 257 $27,139

(ii) The Agency Tally

Bottom-Line Annual Agency Burden and Cost

Agency

Hours For Each 

Number 

of Hours 

Labor 

Cost Per 

Overhead 

Cost Per 

Total

Agency
Review Per Year Year Year Cost per 

Year

Agency Total

(DFO &DEO) 

For 300 

Respondents

120 min./ 2 

hours

2.00

514 $35,209 $21,125 $56,334

6(f) Reasons for Change in Burden

There is a decrease of 43 hours in from the currently approved burden due to more 

precise estimates of the number of SGEs filling out Form 3110-48, based on the average number 

of forms received in the last 3 years.

6(g) Burden Statement

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

collection of information is estimated to average one hour 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-OA-2010-0757, which is available for online viewing at 

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

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 

Docket is (202) 566-9744. 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 EPAHQ-OA-2010-0757 and OMB Control No. 2090-0029 in any correspondence.