1 **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 EPA’s**  **Safer Choice Product Recognition**  **Program ICR Numbers:**  **EP A ICR No. 2302.0**  **3 OMB Control No. 2070**  **- 0178**  **1(b) Short Characterization / Abstract**  This renewal information collection request (I CR) addresses the submission of applications to EPA for recognition under the Safer Choice Product Recognition Program ( Safer Choice program ) , formerl y known as the Design for the Environment Program
. The Safer Choice program recognizes products where all ingredients meet EPA’s stringent requirements for human health and the environment as found in the Safer Choice Standard. Under the encouragement of the current p rogram, leading companies have already made great progress in developing safer, highl y effective chemical products
. Since the program’s inception in 1997, formulators have been using the program as a portal to OPPT’s unique chemical expertise, information resources, and guidance on greener chemistry
. Safer Choice partners enjo y Agency recognition, including the use of the Safer Choice label on qualifying products
. This I CR would enable Safer Choice to accommodate participation by more than nine formulators each ye ar , enhance program transparency , and f urther promote chemical safet y . Safer Choice participates in the development of CleanGredientsTM, a database of safer cleaning product ingredients, which identifies safer formulations and makes forming partnerships easier
. Organized by

product functional u se class (e.g., surfactants, solvents, etc.), CleanGredientsTM facilitates a green marketplace where formulators can select functionall y appropriate and safer ingredients. The redesign of chemical products offers opportunities to:

 Remove hazardous chemicals from formulations before they can enter the w orkplace, home, or environment.  Advance energy

and water efficiency , resource conservation, and innovative technologies.  Qualify

for environmentally

preferred product status, increasingl y sought by go vernment, re tailer and consumer purchasers. Companies formulate products from a broad range of chemicals with a variety of applications
. The Safer Choice p rogram labels cleaning and other chemical
- based products such as dish detergents, laundry deterge nt s , hand soaps, and all
- purpose cleaners for consumer and industrial use
. Cleaning products make up the majority of partnership products, and cleaning product manufacturers have the greatest demand for program participation b y potential partners
. Third
- party profilers review all product applications prior to Safer Choice submission. The review team carefully reviews each product component
. A literature review, and when appropriate, structural activity relationships, are used to understand each chemical’s hea lth and2

environmental characteristics. The review includes all chemicals, including those in proprietary raw material blends, which ingredient suppliers share with Safer Choice and the third
- part y profilers in confidentiality . The review team then compares an ingredient’s characteristics to other chemicals in the same use class, considers possible negative sy nergies between ingredients, and places the ingredient on a continuum of improvement relative to other similar chemicals
. By means of its review team and methodology , Safer Choice provides information to formulators that helps them select from among the safest chemicals in an ingredient class
. Onl y formulations containing exclusively safer ingredients are recognized b y Safer Choice
. **2. NEED FOR AND USE OF THE COLLECTION**  **2(a) Need/Authority for the Collection**  Authority for the Safer Choice p rogram derives from Section 6604(b)(5) of the Pollution Prevention Act (PPA), 42 U.S.C. 13103(b)(5) ( see Attachment A ) , which directs EPA to facilitate the adoption of source
- reduction techniques by businesses, and the Toxic Substances Control Act (15 U.S.C. 2601 et seq.), which encourages safet y in technological innovation in chemistry
. In recognition of this statutory

dir ective, and through consultation with a broad range of stakeholders, EPA developed the Safer Choice p rogram. Safer Choice p rogram information collection activities will assist the Agency in meeting the goals of the PPA by

providing resources and recogniti on for businesses committed to promoting and using safer chemical products
. Inturn, the Safer Choice p rogram will help businesses meet corporate sustainability

goals by providing the means to, and an objective measure of, environmental stewardship. Investment anal ys ts and advisers seek these ty pes of measures in evaluating a corporation’s sustainability profile and investment worthiness. 1 Itis not surprising then that EPA has heard from man y organizations that Safer Choice p rogram partnership is an important impetus for prioritizing and completing the transition to safer chemical products
. The Safer Choice p rogram is also needed to promote greater use of safer chemical products by companies unaware of the benefits of such a change. Safer Choice has caref

ully tailored its request for information, and especially the Safer Choice p rogram application forms , to ensure that it only asks for information essential to verifying applicants’ eligibility for recognition. **2(b) Practical**  **Utility/Users of the Data** The information collected by the Safer Choice p rogram is not designed or intended to support regulatory

decision
- making by

EPA. EPA uses the information collected in the Safer Choice p rogram application to: (1) review products an d their components; (2) complete chemical profiles for each product component to determine its key health and environmental characteristics; and (3) establish a partnership agreement with the compan y outlining how the compan y and EPA/ Safer Choice will work together to continually

improve the health and environmental profile of the product(s)
.

1 “ Green to Gold: How

Smart Companies use environmental strategy to innovate, create value, and build competitive advantage" by Daniel Esty and Andrew Winston, Yale University Press, New Haven, 20063

**3. NON -**  **DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA 3(a)**  **Non -**  **Duplication** Respondents will not be asked to provide informatio n that has been or is currentl y being collected b y EPA, other federal or state agencies, or proprietary sources. The information collected by the Safer Choice p rogram is unique and is not duplicative of previous information collection requests. As due dil igence, EPA also checked with trade associations and potential partners to confirm that the information being collected by the Safer Choice 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 comple ting the supporting statement that is submitted to OMB. **3(c) Consultations**  Under 5 CFR 1320.8(d)(1) OMB requires agencies to consult with potential I CR respondents and data users about specific aspects of IC Rs before submitting an original or renewal ICR to OMB for review and approval. In accordance with this regulation, EPA will pursue additional consultations with interested parties during the development of the renewal of this collection. **3(d) Effects of L**  **ess Frequent Collection** Safer Choice p rogram applications will be received on an ongoing basis over the three ye ars covered b y this ICR. The applications are designed to be one
- time information submissions for organizations that wish to participate in the Safer Choice p rogram, with the opportunity to renew the partnership agreement at the end of the three
- ye ar partnership period
. This means that once every three ye ars, the organization will submit a renewal application to confirm that no changes have been made to ingredients; this step is done in response to correspondence from Safer Choice that reminds organizations of the terms of their partnership agreements. Without this information collection mechanism, Safer Choice will not have the ability to assist formulators in developing safer, highl y effective chemical products or to formall y recognize formulators who have successfull y done so. **3(e) General Guidelines**  The information collection activities discussed in this renewal ICR com pl y with all regulatory guidel ines under 5 CFR 1320.5(d)(2). **3(f) Confidentiality**  Some information collected by EPA under the Safer Choice p rogram involves confidential business (CBI) or trade secret information. The Safer Choice p rogram handles all information claimed as confidential business information in accordance with Agency confidentiality

procedures (se e 40 CFR part 2, subpart B). The Safer Choice p rogram uses information provided by formulators solely

for purposes related t o forming the partnership and discloses the information only to EPA employ ees and EPA contractors cleared for confidential information with a specific need to know.4

**3(g) Sensitive Questions**  The information collection activities do e s not involve an y sensitive questions.
**4. THE RESPONDENTS AND THE INFORMATION REQUESTED**  **4(a) Respondents and NAICS Codes**  The Safer Choice p rogram seeks partners from establishments engaged in the formulation of end
- us e, for
- sale chemical products. Below is a list of representative North American Industry Classification S ystem (NAICS) codes and associated industries that may be affected b y i nformation collection requirements covered under this I CR. This list is intended to be illu strative; entities from other industries may elect to appl y for recognition through the Safer Choice p rogram. However, EPA expects that most applications will come from the following industries: NAI CS Code Affected Industry 325510 Paint and Coating Manufa cturing 325611 Soap and Other Detergent Manufacturing 325612 Polish and Other Sanitation Good Manufacturing 325910 Printing Ink Manufacturing 325992 Photographic Film, Paper, Plate, and Chemical Manufacturing 325998 All Other Miscellaneous Ch emical Product and Preparation Manufacturing **4(b) Information Requested**  Once a compan y with an interest in partnership with the Safer Choice p rogram reviews the program materials and decides to apply , the next step for the organization is to submi t the appropriate app lication. (i) Data items : Applicants for this voluntary program submit information items that vary depend ing upon the class of product. The items include: **Partnership Applications** P roduct manufacturers will submit ingredient information, as described here, through a cloud
based Salesforce s ys tem, to a qualified third
- party profiler before submittal to EPA (see Attachment B). Information submitted to third

- part y profilers :  Company

name and Web site URL ;  Number of emplo ye es;  Company

headquarters address and manufacturing address;5

 Name, title, phone number, and e
- mail address of the candidate’s signatory contact person (e.g., CEO, or vice president for health and environment) ;  N ame, tit le , phone number, and e
- mail address of candidate’s technical contact person ;  Name, title, phone number, and e
- mail address of candidate’s marketing/outreach contact person;  Product information (name (s) , UPC, GSA number, sector, production volume, pH, flas hpoint, product form , product use );  Product characteristics on whether or not the product is: o An EPA registered pesticide ; o A direct release product ; o A concentrate ; o Contains enzy

mes, fragrance, or VOCs ; o Requires hazard labeling ; o In gredient disclosure and pe rformance data submitted ;  Packaging information : o Container size and shapes; o Material; o Supplier;  Description of all chemical ingredients , including raw materials and alternative ingredients, in product : o CAS number; o Chemical name; o Trade name ; o Percent composition; o In gredient class; o Supplier name;  An SDS for the product and each ingredient;  Product performance testing (an y m ethod of demonstrating product performance is acceptable as long as it is a co mmonly used industry

standard);  Other product informat ion specific to particular product classes, such as flushability / compostability for disposable cleaning wipes;  If available, an y supplemental product or ingredient environmental health and safet y information, such as: o Biodegradation tests on individual i ngredients ; o Acute aquatic toxicity tests on product as a whole or individual ingredients ; o Human health and safet y tests ;  Description of the t ype of training the compan y provides to customers on environmental and worker safety

matters
. Information submitte d to EPA :  Summary

report, containing same data items as above
. **Adding Third -**  **Party Partners and Products** Cleaning product manufacturers will submit information about third
- part y additions to Safer Choice through their third
- part y profiler
. The three ty pes of third
- party

partners and products are private labels, licensees, and toll manufacturers. To be label
- eligible, third
- party product s must contain ingredients identical to those in a Safer Choice
- labeled product.6

Information submitted to EPA :  Safer Choi ce Form for Adding Third
- Party Partn ers and Products (Private Label Companies, L icensees, or Toll Manufacturers) (EPA Form XXXX
- X) (See Attachment C ) Note that this form will be incorporated into the Salesforce system in the coming months. The fields in the online form in Salesforce will be identical to the PDF form. Until this part of the system is fully incorporated, the Agency will continue to use the PDF application form in Attachment C. (ii) Respondent activities : Applicants for Cleaning and Non

- Cleaning Product Formulation Partnerships  Review program information, including instructions on submitting information to third
party profilers (note: third
- part y profilers are separate and distinct from third
- part y partners and products; a third
- party profiler is an organization that has partnered with the Safer Choice Program to assist in the evaluation of product formulations against the Safer Choice Standard. To become a third
- part y profiler, the organization must meet stringent requirements as laid out in Sect ion 7 of the Safer Choice Standard .)  Submit information described in section 4(b)(i) of this supporting statement to third
- party profiler ;  Establish agreement with third
- part y profiler ;  Submit summary

report to Safer Choice ;  Negotiate / establish Partnership Agreement with Safer Choice ;  Renew partnership, with no changes needed ;  Site audit (See Attachment D )
. Adding Third

-Party Partners and Products  Review program information ;  Fill out and submit Safer Choice Program Form for Adding Third
- Part y Partners and Products (Private Label Companies, L icensees, or Toll Manufacturers)
. **5. THE INFORMATION COLLECTED** 

**– AGENCY ACTIVITIES, COLLECTION**  **METHODOLOGY, AND INFORMATION MANAGEMENT 5(a)**  **Agency Activiti es**  Under the Safer Choice p rogram, EPA engages in the following activities related to the Formulator application and decision process :

 P rovide applications via Salesforce for potential participants;  Answer questions posed by potential applicants regardin g recognition under the program ;  Receive the completed applications, review for accuracy, and place any necessary follow
- up calls;  Apply EPA’s chemical tools and expertise to understand toxicological characteristics of chemical ingredients and to ensure that they are the safest within their functional use class;7

 Approve candidates for recognition and notify both successful and unsuccessful applicants of the decisions ; and  Make final decisions about which products may carry the Safer Choice label. **5(b) Collection Methodology and Management**  P roduct manufacturers may obtain applications for providing ingredient information by contacting a third
- part y profiler. The third
- part y profiler will then coordinate with EPA to direct the potential applicant to a link via Salesforce to complete the application online. If a product manufacturer would like to submit information that they believe is Confidential Business Information as defined under the Toxic Substances Control Act, the applic ant should contact EPA by phone. In collecting and anal yz ing the information associated with this I CR, EPA will use a telephone sy stem, personal computers, and applicable database software such as Salesforce . EPA will ensure the accuracy and completeness of collected information by reserving the right to request proof of the list of ingredients (e.g., bills of lading, invoices) or other relevant documentation at an y time to confirm that candidates have the achieved the criteria for recognition. Th e cloud
- b ased Salesforce s ys tem, which house s applications and other information related to the Safer Choice program , is designed to reduce the public and Agency

burden related to the application and decision process. However, if a product manufacturer would like t o submit information as a hard cop y rather than using the Salesforce s ys tem, the applicant should contact EPA for the appropriate forms. **5(c) Small Entity Flexibility**  EPA expects that some of the participants in the Safer Choice p r ogram will be small entities. EPA has designed its application form to minimize respondent burden while obtaining suffic ient and accurate information. In addition, given the voluntary nature of the collection, EPA expects that respondents will participate only if the benefits of participation outweigh the information collection burden. **5(d) Collection Schedule**  Organizations may

submit an application for recognition at any time.
**6. ESTIMATING THE BURDEN AND**  **COST OF THE COLLECTION 6(a)**  **Estimating Respondent Burden** The average respondent burden is estimated to be 16 hours for new product formulators and 8 hours for product formulators wishing to add third
- part y partners and products (see Exhibit 6.2). EPA us ed professional judgment to arrive at a burden estimate and then consulted representatives from the participant categories to make sure the burden estimates were reasonable (see section 3(c)). EPA expects that for a t ypical product formulator, program and application review will take about 2 hours (1 managerial, 1 technical)
. Filling out and submitting third
- party profiler information request forms will take about 6 hours ( 5 technical, 1 clerical), and then establishing an agreement with the third
- part y profiler will take about 3 hours (1 managerial, 1 technical, 1 clerical)
. Submitting a8

summary report to Safer Choice will take about 2 hours (1 managerial, 1 technical)
. Finally , establishing a Partnership Agreement with Safer Choice will take 3 hours (1 managerial, 2 technical). For a t ypical addition of a third
- part y partner and products, program and application review will take about 2 hours (1 managerial, 1 technical). Filling out and submitting one Safer Choice Program Form for Adding Third
- Party Partners and Products (Private Label Companies, L icensees, or Toll Manufacturers) is estimated to take about 2 hours ( 1.5 technical , 0.5 clerical ). On average, a partner will fill out 3 third
- part y partners and products forms annuall y. Therefore, it is estimated that it will take one respondent 6 hours ( 4.5 technical , 1.5 clerical) to add third
- party partners and products. In addition to the burden associated with first
- time submission of applications, each formulator has the opportunity

to renew its Partnership Agreement at the end of the three
- ye ar partnership period. This means that once every three y ears, the formulator re
- submits its application for each partnership product to confirm that no changes have been made to ingredients
. EPA then evaluates the application
. EPA estimates that the partnership renewal process will take 4 hours ( 3 technical, 1 clerical) for cleaning and non
- cleaning product formulators. For purposes of this I CR, EPA expects that 108 (see Section 6 (e) on estimating the respondent universe) product formulators will choose to renew their partnerships
. Furthermore, EPA anticipates that one in ten product formulators (i.e., 12) over the three
- year period of this I CR will need to make improvements to their formulations so that they contain the safest ingredients within each functional use class; in these cases, a new partnership approval process, as described above, will be trigge red
. The associated burden for completing the new partnership approval process is assumed to be the same as first
- time submission. As part of the application process, the third
- part y profiler will also reserve the right to conduct site audits and desk aud its
. The purpose of site visit s to facilities is to verify that each partnership product contains the same ingredients, in the same volumes, that are reported by the company

as part of the Safer Choice recognition process
. The site auditor will review batc h tickets associated with each recognized product to ensure that ingredient claims are accurate
. Additional audit procedures are listed in Attachment D of this document. For purposes of estimating annual cost and burden in Exhibit 6.2, it is assumed that a

bout 33% of formulators will get audited on - site each ye ar over the three
- ye ar period of this I CR
. Each site audit is estimated to require two hours of a technical person’s time and one hour of a clerical person’s time. Desk audits will also be conducted b y third
- party profilers. Prior to the desk audit, formulators will be responsible for providing a list of all ingredients for each recognized product, product labels displaying the Safer Choice logo, private label information (where applicable), and variou s other materials. For the purposes of estimating annual cost and burden in Exhibit 6.2, it is assumed that 66% of formulators will be subject to a desk audit each y ear over the three
- ye ar period of this I CR. Each desk audit is estimated to require two hours of a technical person’s time and two hours of a clerical person’s time. As with the site audits, additional information on desk audits can be found in Attachment D of this document. **6(b) Estimating Respondent Costs**  EPA estimates an average loaded h ourl y labor rate (base hourly rate plus fringe and overhead) of $ 8 3 for managerial staff, $ 73 for technical staff, and $ 32 for clerical staff. These three labor rate estimates are based upon manufacturing industry wage data from the Bureau of Labor Statist ics (BLS) Employer Costs for Employee Compensation, Supplementary Tables from September 2015 . The hourly labor rates include a 17% overhead; this overhead rate is used for consistency with OPPT9

economic analy ses for two major rulemakings: Wage Rates for Economic Analyses of the Toxics Release Inventory Program 2 and the Revised Economic Analysis for the Amended Inventory Update Rule: Final Report
. 3 In addition, the hourly labor rates have been rounded for the purposes of this ICR. The ty pe of staff needed to complete the Formulator’s applications and their associated hourly labor rates were verified b y contacting representatives from the participant categories. The derivation of labor rates for managerial, technical, and clerical staff appears in Exhibit 6.1. **Exhibit 6.1. Derivation of Loaded Wage Rates in**  **2015 $**  **Labor category**  **Wage Fringe**  **Benefit Fringes as** 

**% wage Overhead** 

**% wage**  **Fringe +**

**overhead factor**  **Loaded**

**Wages Loaded** 

**Wages (rounded)**  **(a) (b)**  **(c)=(b)/(a) (d)**  **(e)=(c)+(d)+1 (f)=(a)**   **(e) Managerial** **4** $ 49.78 $ 24.70 49.62 % 17% 1. 67 $ 82.94 $ 83 .00 **Professional/ Technical**  **2** $ 42.76 $ 23.07 53.95 % 17% 1. 71 $ 73.10 $ 73 .00 **Clerical 2**  $ 19.04 $ 9. 61 50. 47 % 17% 1.6 7 $ 31.89 $ 3 2 .00 In exhibit 6.2 is the breakdown of burden costs, assuming 16 hours for completing the partnership agreement , 11 hours for renewals and associated audits, and 8 hours for cleaning product formulators wishing to add third
- part y partners and products
. The third
- party profiler verification process for cleaning products also adds an operating and management (O&M) cost of about $ 12,400 per compan y per application. Thi s cost estimate is from NSF International, which has experience as a third
- part y profiler of ingredient characteristics. For this I CR, it is assumed that ty pical product manufacturer s will submit four prod ucts in an application. Each product is assumed to contain 2 ingredients at $ 650 each, 1 proprietary ingredient at $ 1,300 each, and 3 CleanGredients TM ingredient at no charge, for a total of $ 2 , 6 00 per product. In addition, a $ 500 administrative fee per product is assumed. The total will be $ 12,400 per comp an y per application. No additional capital or O&M costs are incurred b y respondents under this I CR.

2 EPA, 2002b. 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. 3 EPA, 2002 . U.S. EPA, Office of Pollution Prevention and To xics, Economic and Policy Analysis Branch. Revised Economic Analysis for the Amended Inventory Update Rule: Final Report. Washington, DC. August 2002. 4 Bureau of Labor Statistics (BLS) Employer Costs for Employee Compensation, Supplementary Tables. From Supplementary Table 2, Employer costs per hour worked for employee compensation and costs as a percent of total compensation: Private industry workers in manufacturing industries, by occupational group, establishment size and bargaining status, Septem ber 2015
. Available at: http://www.bls.gov/ncs/ect/sp/ ecsuptc 36 .pdf10

**Exhibit 6.2. Estimated Annual Burden and Costs to Respondents**

**Collection activity**  **Hours and Costs Per Respondent Total Hours and Costs**  **Mgr. Tech.**  **Cler. Response**  **Hours/Yr Labor** 

**Cost/Year Capital**  **O & M Cost** * **Number of**

**Respon.  ** Total**

**Hours/Yr Total** 

**Cost/Yr $**  **83 /Hr**  **$ 73**  **/Hr $**  **32 /Hr**  **Cost Partnership Agreements**  Review program inf

orm ation 1.0 1.0
- 2.0 $ 156 $0 $0 4 4 8 8 $ 6, 864 Fill out and submit third
- party information request form

- 5 .0 1. 0 6.0 $ 397 $0 $0 44 2 64 $ 17,468 Establish agreement with third
- party profiler 1.0 1.0 1.0 3.0 $ 18 8 $0 $12,400 44 1 32 $ 553,872 Submit summary report to Safer Choice 1.0 1.0
- 2.0 $ 156 $0 $0 44 88 $ 6,684 Negotiate / establish Partnership Agreement w ith Safer Choice 1.0 2.0
- 3.0 $ 229 $0 $0 44 1 32 $ 10,076 Subtotal 4.0 10.0 2.0 16.0 $ 1,126 $0 $12,400 44 704 $ 595,144 **Renew als and Audits**  Renew partnership, w ith no changes needed

- 3 .0 1.0 4 .0 $ 251 $0 $0 36 144 $ 9,036 Desk audit

- 2.0 2.0 4.0 $ 210 $0 $0 2 4 96 $ 5,040 Site audit

- 2.0 1.0 3.0 $ 178 $0 $0 1 2 36 $ 2,136 Subtotal

- 7.0 4

. 0 11 .0 $ 639 $0 $ 0 36 276 $ 16,212 **Adding Third -**  **Party Partners and Products** Review program information 1.0 1.0
- 2.0 $ 156 $0 $0 77 154 $ 12,012 Fill out and submit form for adding third
party partners and products

- 4.5 1.5 6.0 $ 377 $0 $0 77 462 $ 28,991 Subtotal 1.0 5.5 1.5 8.0 $ 533 $0 $0 77 6 16 $ 41,003 **TOTAL 1**  **5 7**  **1,5 96**  **$ 652,359**  * The cost for third
- party profiler review and verification assumes that the typical application submitted by a cleaning product manufacturer will contain four products , each with 2 ingredients ( $ 650 each ), 1 proprietary ingredient ( $ 1,300 ) , and a $ 500 administrative fee. The total cost per product is $3,100. The total will be $ 12,400 per company per application. **This column reports the number of annual respondents after accounting for the partnership renewal process. Assumes that on e in ten formulators over the three
- year period will need to make changes to their formulations and go through a new partnership pr ocess which includes same collection steps. On an annual basis, this translates to 4 product formulators (for a total of 44 partnership agreements ). Also assumes that about 33% of the remaining product formulators will be subject to site audits each year (i.e., 12) and that about 66% (i.e., 24) will be subject to desk audits each year
. See Section 6(a) for additional explanation. Assu mes that 77 partners will fill out third
- party partners and products forms based on historical data
. See Section 6(e) for a dditional explanation.11

**6(c) Estimating Agency Burden**  Exhibit 6.3 presents the estimated Agency burden hours and costs associated with the information collection activities under this I CR
. EPA based its burden estimates on its experience managing other voluntary programs. EPA expects that review of the program application forms for a t ypical product formulator will take about 1 hour (1 technical)
. Reviewing the third
- part y profiler information summary report wi ll take abo ut 5 hours (5 technical). Establishing a Partnership Agreement with the formulator will take about 3 hour s ( 1 managerial, 2 technical). Reviewing the partnership renewal and assuming that no changes are needed is estimated at 2 hours (1 managerial, 1 technical) , and reviewing audit summaries is estimated at 1 hour (1 technical). The burden f

or r eviewing the Safer Choice Form for a dding third
- party partners and p roducts is estimated to take about 2 hours ( 2 technical). **6(d) Estimating Ag**  **ency Costs** Agency labor costs are calculated based on hourly basic rates for federal employ ees in the Washington
- Baltimore area published b y the Office of Personnel Management effective January 2016 5

. The average hourly labor rate for managerial staff is estimated as the rate for a GS
- 13 Step 5 employ ee, for technical staff as a GS
- 10 Step 10 employ ee, and for clerical staff as GS
- 5 Step 1
. These GS
- level assumptions are consistent with those used in past EPA OPPT ICRs
. The hourl y rates were multiplied by an assumed loading factor of 1.6 to reflect Federal fringe benefits and overhead
. This loading factor is from an EPA guide, Instructions for Preparing Information Collection Requests (ICRs) (OPPE, 1992, page 30, footnote 9)
. The resulting average hourly l abor rates, rounded to the nearest dollar amount, are $ 80 for managerial staff, $ 59 for technical staff, and $ 27 for clerical staff
. The Agency

expects most activities related to this I CR to be performed by managerial staff ( 14 percent) and technical staff ( 86 percent).

5 OPM, 2016 . Salary Table 2016
- DCB , Washington Baltimore Northern Virginia, DC

-MD

-PA

- VA

- WV

. Available at http://www.opm.gov/oca/ 1 6 tables /pdf/dcb_h.pdf12

**Exhibit 6.3. Annual Agency Burden/Cost**

**Collection activity Hours and Costs Per Respondent**  **Total Hours and Costs Mgr.**  **$ 80**  **/Hr Technical** 

**$5 9**  **/Hr Agency** 

**Hours/Yr Labor** 

**Cost/Year Capital/** 

**Startup Cost O & M** 

**Cost Number of** 

**Respon.*** **Total**

**Hours/Yr Total** 

**Cost/Yr Cleaning and Non**  **- Cleaning Products**  Review program application forms

- 1.0 1.0 $ 59 $0 $0 4 4 4 4 $ 2, 596 Review third
- party profiler summary

- 5 .0 5 .0 $ 295 $0 $0 44 22 0 $ 1 2,980 Negotiate / establish Partnership Agreement w ith formulator 1 .0 2 .0 3 .0 $ 198 $0 $0 44 1 32 $ 8,712 Review partnership renewal, with no changes needed 1.0 1.0 2.0 $ 139 $0 $0 36 72 $ 5,004 Review audit summaries

- 1.0 1.0 $ 59 $0 $0 36 36 $ 2,124 Subtotal 2 .0 10.0 12.0 $ 750 $0 $0 8 0 504 $ 31,416 **Adding Third -**  **Party Partners and Products** Review Safer Choice form for adding third
- party partners and products
- 2 .0 2.0 $ 118 $0 $0 77 1 54 $ 9,086 Subtotal

- 2.0 2.0 $ 118 $0 $0 77 1 54 $ 9,086 **TOTAL 157**  **6 58**  **$ 40,502**  * This column reports the number of respondents after accounting for the partnership renewal process. Assumes that one in ten formulators will need to make changes to their formulations and go through a new partnership process which includes same collection steps , i.e . 4, for a total of 44 annually. Assumes that 77 partners will fill out third
- party partners and products forms based on historical data
.13

**6( e**  **) Estimating the Respondent Universe and Total Burden and**  **Costs** EPA estimates that 120 formulators will submit applications over the three - ye ar life of the clearance. EPA expects the participation will ramp up over the three y ear period but , for the purposes of estimating annual cost and burden in Exhibit 6.2, it is assumed that 40 product formulator application s will be submitted each year. This estimate is based on historical data and the assumption that participation will increase over the next three y ears in response to greater consumer demand for safer products and increased awareness of the Safer Choice label. EPA also expects 40 renewals per year, 10% of which will need to make changes to formulations and go through a new partnership pr ocess. Additionally, EPA estimates that 77 applications will be received annuall y to add third
- part y partners and products. This estimate is based on the average number of partners that submitted third
- party partners and products applications over the past five y ears (62) and is expected to increase over the course of this ICR period due to the new label (25%). Therefore, it is estimated that a total of 157 respondents will submit applications under the Formulator program each ye ar. The annual burden hours and cost associated with this information collection are 1,596 hours and $652,359 respectivel y. **6( f**  **) Bottom Line Burden Hours and Cost Tables** 
a. Respondent Tally Exhibit 6.4 below summarizes the total annual estimat ed respondent burden and cost. These estimates represent the average burden in any given ye ar over the three ye ars covered b y this I CR. **Exhibit 6.4. Total Annual Estimated Respondent Burden and Cost Summary Total # of Respondents**  **Total Burden Hours**  **Annua l Cost** 

157 1, 596 $ 652,359 b. Agency

Tall y Exhibit 6.5 below summarizes the total annual est imated agency burden and cost. These estimates represent the average burden in an y given y ear over the three y ears covered by this ICR. **Exhibit 6.5. Total Annual Estimated Agency Burden and Cost Summary** 

**Burden Hours Annual Cost**  6 58 $ 40,502 **6( g**  **) Reasons for Change in Burden**  This request reflects an in crease in the estimated annual burden of 362 hours (from 1,234 hours to 1,596 hours) from that currentl y in the OMB inventory
. EPA reduced p er - response b urden estimates compared to those in the previous I CR based on expected efficiencies created by using the Salesforce
- based Safer Choice Community on the part of respondents. Howeve r, the14

number of respondents increased , compared to the prior I CR , due to historical experience and increases in the expected future number of responses due to greater consumer awareness and demand for products with the Safer Choice label
. Th i s change i s an adjustment
. **6( h**  **) Burden Statement**  The annual public burden for this collection of information is estimated at 16 hours per response for formulators , 11 hours for formulators renewing a partnership that requires changes, and 8 hours for cleaning product formulators wishing to add third
- part y partners and products , 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 no t conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currentl y valid OMB control number. The OMB control numbers for EPA’s regulations in title 40 of the CFR, after appearing in the Federal Regi ster, are listed in 40 CFR part 9 and included on the related collection instrument or form, if applicable. The Agency

has established a public docket for this I CR under Docket ID No. EPA
- HQ
OPPT
- 20 15
- 0437 , which is available for online viewing at www.regulations.gov, or in person viewing at the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday

through Fri day , excluding legal hol iday s. The telephone number for the 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 pro vided burden estimates and an y suggested methods for minimizing respondent burden, including the use of automated collection techniques. Submit your comments, referencing Docket ID No. EPA
- HQ
- OPPT
- 2015
- 0437 and OMB Control No. 2070
- 0178 , to (1) EPA online using www.regulations.gov (our preferred method), or b y mail to: Document Control Office (DCO), Office of Pollution Prevention and Toxics (OPPT), Environmental Protection Agency , Mail Code: 7407T, 1200 Pennsylvania Ave., NW, Washington, D.C. 20460, and (2 ) OMB b y m ail to: Office of Information and Regulatory Affairs, Office of Management and Budget (OMB), Attention: Desk Officer for EPA, 725 17th Street, NW, Washington, DC 20503.15 **ATTACHMENTS TO THE SUPPORTING STATEMENT** Attachments to the supporting stat ement are available in the public docket established for this I CR under docket identification number EPA

–HQ

– OPPT

–2008

– 0219. These attachments are available for online viewing at www.regulations.gov or otherwise accessed as described in section 6(g) 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 US Code website **Attachment B: Safer Choice Program: Produ**  **ct and Ingredient Submissions in**

**Salesforce Attachment**  **C :**  **Safer Choice Program: Form for Adding Third -**  **Party Partners and**

**Products (Private Label Companies, Licensees, or Toll M**  **anufacturers) Attachment**  **D :**  **Safer Choice Program: Audit Process Guidance**