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Supporting Statement for a Request for OMB Review under

The Paperwork Reduction Act

1 IDENTIFICATION OF THE INFORMATION COLLECTION

1(a) Title of the Information Collection: 

EPA’s Safer Choice Partner of the Year Awards Program

ICR Numbers: EPA ICR No. 2450.02 OMB Control No.: 2070-0184

1(b) Short Characterization / Abstract

This information collection request (ICR) renewal addresses the submission of applications to 

EPA’s Safer Choice Program for recognition under the Partner of the Year (PY) Awards Program. 

Note that the original ICR (OMB Control No 2070-0184) referred to the Design for the Environment 

(DfE) PY Awards Program. The DfE Program changed its name to the Safer Choice Program in 

March 2015. This ICR renewal reflects the program’s new name. The intent and purpose of the PY 

Awards Program remains unchanged.

The goal of the PY Awards Program is to recognize Safer Choice stakeholders who have 

furthered Safer Choice’s safer chemistry goals through their active and exemplary participation in and 

promotion of the Program. Making Safer Choice’s mission known to the widest possible audience, 

through its safer product label and in other forms of communication, is critical to fully realizing the 

program’s goals of protecting human health and the environment, promoting a sustainable economy, 

and creating green jobs, especially in the small business sector. EPA hosted its inaugural PY Awards 

in June 2015 and recognized 21 organizations in five categories. Furthermore, Executive Order 13693, 

issued February 19, 2015, recognizes the Safer Choice program as one of the ways to promote Federal 

sustainability.

The PY Awards will be an annual event, with recognition for Safer Choice stakeholder 

organizations from five broad categories: (1) Formulators/Product Manufacturers (of both consumer 

and Institutional/Industrial (I/I) products), (2) Purchasers and Distributors, (3) Retailers, (4) Supporters

(e.g., non-governmental organizations, including environmental and health advocates, trade 

associations, academia, sports teams, and others), and (5) Innovators (e.g., chemical manufacturers, 

technology developers, and others). Within these categories and based on the criteria, Safer Choice

may elect to give an additional award in the subcategories of “small business” and “sustained 

excellence.” 

Candidates will complete an application that describes the actions taken to qualify for 

recognition and have it signed by a company or organization authority (e.g., CEO, vice president for 

governmental affairs, division head, or other authorized signatory).
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2. NEED FOR AND USE OF THE COLLECTION

2(a) Need/Authority for the Collection

Authority for PY derives 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 awards program to recognize a company or companies that operate outstanding or innovative 

source reduction programs. EPA developed PY in recognition of these directives and through 

consultation with a broad range of stakeholders. 

The information collection activities for PY will assist the Agency in meeting the goals of the 

PPA by providing recognition for organizations committed to promoting and using safer chemicals. In 

turn, PY will help organizations meet their sustainability goals by providing the means to, and an 

objective measure of, environmental stewardship. Investment analysts and advisers often seek these 

types of measures in evaluating a corporation’s sustainability profile and investment worthiness.1 PY

is also an incentive for promoting the greater use of safer chemicals by organizations EPA has 

carefully tailored its request for information, especially the PY Application Form, to ensure that it only

asks for information essential to verifying an applicant’s eligibility for award or recognition. 

2(b) Practical Utility/Users of the Data

The information collected by the PY Awards Program is not designed or intended to support 

regulatory decision-making by EPA. EPA uses the information collected in the PY Application Form 

to: (1) identify the candidate’s commitment to promoting and using safer chemicals; (2) verify the 

candidate’s involvement in promoting and using safer chemicals; and (3) determine the candidate’s 

eligibility for PY award or recognition.

3. NON-DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA

3(a) Non-Duplication

Respondents will not be asked to provide information that has been or is currently being 

collected by EPA, other federal or state agencies, or proprietary sources. The information collected by

the PY Awards Program is unique and is not duplicative of previous information collection requests. 

EPA also checked with potential respondents (e.g., trade associations) to confirm that the information 

being collected by the PY Awards Program does not exist elsewhere.

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

Prior to submission to OMB, this ICR will be made available to the public for comment 

through a Federal Register notice. The public will have 60 days to provide comments. Any comments 

received will be given consideration when completing the supporting statement that is submitted to 

OMB.

 

1

“Green to Gold: How Smart Companies Use Environmental Strategy to Innovate, Create Value, and Build Competitive Advantage;” 

Daniel Esty and Andrew Winston; Yale University Press, New Haven, CT; 2006
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3(c) Consultations

Under 5 CFR 1320.8(d)(1) OMB requires agencies to consult with potential ICR respondents 

and data users about specific aspects of ICRs before submitting an 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 Less Frequent Collection

The PY Application Form is designed to be an annual information submission for organizations 

that wish to apply for recognition. Without this information, EPA will not be able to effectively

determine and formally recognize the extent to which organizations are engaged in activities to 

promote the use of Safer Choice-labeled products and actions to advance the program.

3(e) General Guidelines

The information collection activities discussed in this ICR comply with all regulatory

guidelines under 5 CFR 1320.5(d)(2). 

3(f) Confidentiality

No information collected by EPA under PY comprises confidential business information as 

defined by EPA’s confidentiality regulations (40 CFR 2.201 et seq.).

3(g) Sensitive Questions

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

questions involving sexuality, religious beliefs, political affiliation, or other matters considered private, 

as described in the document “The Paperwork Reduction Act of 1995: Implementing Guidance for 

OMB Review of Agency Information Collection,” from June 2, 1999.

4. THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a) Respondents and NAICS Codes

Under the PY awards program, EPA seeks applicants from establishments engaged in the 

production, use, and/or advancement of safer chemicals and who have furthered the goals of Safer 

Choice through their active and exemplary participation in and promotion of the program.

Below is a list of North American Industry Classification System (NAICS) codes and 

associated industries that may be affected by information collection requirements covered under this 

ICR. This list is intended to be illustrative; entities from other industries may elect to apply for 

recognition for PY awards. However, EPA expects that most applications will come from the 

following industries:

NAICS Code Affected Industry

325510 Paint and Coating Manufacturing

325611 Soap and Other Detergent Manufacturing
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325612 Polish and Other Sanitation Good Manufacturing

325910 Printing Ink Manufacturing

325992 Photographic Film, Paper, Plate, and Chemical Manufacturing

325998 All Other Miscellaneous Chemical Product and Preparation Manufacturing

561210 Facilities Support Services

561720 Janitorial Services

561740 Carpet and Upholstery Cleaning Services

611310 Colleges, Universities, and Professional Schools

8123 Drycleaning and Laundry Services

921190 Other General Government Support

4(b) Information Requested

Once a prospective organization reviews the PY materials and decides to apply, it should 

submit a PY Application Form (EPA Form 9600-04; see Attachment B for complete form). All forms 

will be available in hard copy and electronic format. Participants can use the hard copy forms they

receive from EPA by mail or download PDF versions of the forms from the Safer Choice website at 

http://www2.epa.gov/saferchoice.

(i) Data items:

The reporting items include:

 Organization name and website URL;

 Name, title, address, phone number, fax number, and e-mail address of the candidate’s primary 

contact person;

 Recognition category (or categories) for which the candidate is applying;

 Indication of whether the organization is a small business;

 Indication of whether the organization should be considered for sustained excellence;

 Descriptions of activities taken to qualify for recognition;

 Signature, name, and title of senior company or organization authority (e.g., CEO, vice 

president for governmental affairs, division head, or other authorized signatory).

a. Respondent activities:

Candidates will conduct the following activities in order to complete and submit the PY

Application Form:

 Review the PY information;

 Decide whether to apply for recognition, and in what recognition category or categories;

 Select a primary contact person for the program;

 Complete the PY Application Form, including obtaining the signature of a company or 

organization authority (e.g., CEO, vice president for governmental affairs, division head, or 

other authorized signatory);

 Describe how their organization meets the evaluation criteria for the relevant recognition;

 Fax, e-mail, or mail the form to EPA;

 Provide relevant documentation to EPA upon request.
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5. THE INFORMATION COLLECTED – AGENCY ACTIVITIES, COLLECTION 

 METHODOLOGY, AND INFORMATION MANAGEMENT

5(a) Agency Activities

EPA engages in the following activities related to the PY Application Form:

 Distribute the PY Application Form to potential participants, and maintain a downloadable 

PDF version on the Safer Choice website;

 Answer questions posed by potential applicants regarding PY recognition; 

 Receive the completed forms, review for completeness and place any necessary follow-up 

calls; 

 Screen applicants to determine their history of civil or criminal EPA enforcement actions; and

 Approve candidates for PY recognition based on evaluation criteria (see Attachment B, Section 

2) and notify both successful and unsuccessful applicants of the decisions.

5(b) Collection Methodology and Management

Respondents will be able to obtain the PY Application Form in hard copy from EPA or by

downloading it from the Safer Choice website. The completed forms can be faxed, e-mailed, or mailed 

to EPA.

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

system, personal computers, and applicable database software. EPA will ensure the accuracy and 

completeness of collected information by reserving the right to request relevant documentation at any

time to confirm that candidates have achieved the criteria for recognition. Based on its experience 

with the Safer Detergents Stewardship Initiative (SDSI) Awards Program in 2008 and the inaugural PY 

Awards Program in 2015, EPA anticipates needing to exercise this right for no more than one 

candidate per participant category and has incorporated the associated burden into section 6 below.

5(c) Small Entity Flexibility

EPA expects that a small number of participants in the PY Awards Program will be small

entities. EPA has designed its application form to minimize respondent burden while obtaining 

sufficient 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 this annual awards program each of the three 

years covered by this ICR.
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6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION

The data collection mechanism for the PY awards is the PY Application Form. In an effort to 

minimize burden and cost, the PY Application Form was designed to contain straightforward 

questions. In addition, one application package will serve all types of participants. The expected 

participant categories for PY are as follows: 

(1) Formulators/Product Manufacturers (of both consumer and Institutional/Industrial (I/I) 

products),

(2) Purchasers and Distributors,

(3) Retailers,

(4) Supporters (e.g., non-governmental organizations, including environmental and health 

advocates, trade associations, academia, sports teams, and others) and

(5) Innovators (e.g., chemical manufacturers, technology developers, and others). 

Within these participant categories, it is expected that participants will be private sector 

institutions. Within the participant category Purchasers and Distributors, about five local or state 

governments are likely to participate, with the remaining participants being private sector institutions. 

6(a) Estimating Respondent Burden

The average respondent burden is estimated to be 15 hours for all participant types. EPA used 

professional judgment to arrive at a burden estimate, as well as its experience with administering the 

PY Awards Program in 2015. Burden hours for the PY application package are for reporting purposes 

only.

EPA expects that for a typical entity, program and application review will take about one hour 

(technical staff). Obtaining approval, which is likely to involve verifying assumptions with staff and 

ensuring support from multiple levels of management, will take about three hours (1 managerial, 1 

technical, 1 clerical). Completing the application form will take about 11 hours (10 technical, 1 

clerical). Included in the application form estimate of 11 hours is the potential applicant burden that 

would be incurred if EPA finds it necessary to verify the accuracy and/or completeness of information 

in an application. For purposes of the burden estimate, EPA assumes that it will need to verify

information from one organization in each participant category. 

6(b) Estimating Respondent Costs

EPA estimates an average loaded hourly labor rate (base hourly rate plus fringe and overhead) 

of $68.36 for managerial staff, $65.41 for technical staff, and $28.22 for clerical staff. These three 

labor rate estimates are based upon manufacturing industry wage data from Employer Costs for 

Employee Compensation Supplementary Tables March 2015 (Supplementary Table 2). In addition, the 

hourly labor rates have been rounded, to the nearest cent, for the purposes of this ICR. The derivation 

of labor rates for managerial, technical, and clerical staff are shown in Exhibit 6.1.
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Exhibit 6.1. Derivation of Total Compensation

Total 

compensation

Wages 

and 

Salaries

Benefit costs

Total Paid 

leave

Supplemental 

pay

Insurance

Retirement 

and 

Savings

Legally 

Required 

Benefits

Managerial $68.36 $44.86 $23.50 $6.18 $2.74 $5.24 $4.98 $4.35

Technical $65.41 $42.40 $23.00 $5.76 $2.77 $5.16 $5.07 $4.23

Clerical $28.22 $18.75 $9.47 $1.96 $0.83 $3.48 $1.05 $2.15

Exhibit 6.2 presents the estimated burden hours and costs for all respondents during each of the 

three years covered under this ICR assuming 15 hours for all participant categories. No capital or 

operations and management costs are incurred by respondents under this ICR, with the possible 

exception of postage and photocopy costs.
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Exhibit 6.2. Estimated Annual Burden and Costs to Respondents

Type of 

Affected 

Public

Collection activity Estimated 

# of 

applicants

Estimated response 

time (hours)

Total burden (hours) Hourly labor cost* Total cost

Mgr. Tech. Cler. Mgr. Tech. Cler. Total Mgr. Tech. Cler.

Private Sector

Formulators/Product 

Manufacturers

22

Review application and 

program information

0 1 0 0 22 0 22 68.36 65.41 28.22 $1,439

Obtain senior approval 1 1 1 22 22 22 66 68.36 65.41 28.22 $3,564

Complete and submit package 0 10 1 0 220 22 242 68.36 65.41 28.22 $15,011

Subtotal 22 1 12 2 22 264 46 330 -- -- -- $20,014

Innovators 9

Review application and 

program information

0 1 0 0 9 0 9 68.36 65.41 28.22 $589

Obtain senior approval 1 1 1 9 9 9 27 68.36 65.41 28.22 $1,458

Complete and submit 

package1

0 10 1 0 90 9 99 68.36 65.41 28.22 $6,141

Subtotal 9 1 12 2 9 108 18 135 -- -- -- $8,187

Retailers 5

Review application and 

program information

0 1 0 0 5 0 5 68.36 65.41 28.22 $327

Obtain senior approval 1 1 1 5 5 5 15 68.36 65.41 28.22 $810

Complete and submit package 0 10 1 0 50 5 55 68.36 65.41 28.22 $3,412

Subtotal 5 1 12 2 5 60 10 75 -- -- -- $4,549

Supporters 9

Review application and 

program information

0 1 0 0 9 0 9 68.36 65.41 28.22 $589

Obtain senior approval 1 1 1 9 9 9 27 68.36 65.41 28.22 $1,458

Complete and submit package 0 10 1 0 90 9 99 68.36 65.41 28.22 $6,141

Subtotal 9 1 12 2 9 108 18 135 -- -- -- $8,187

Private Sector and

Local/State

Governments

Purchasers and 

Distributors

5

Review application and 

program information

0 1 0 0 5 0 5 68.36 65.41 28.22 $327

Obtain senior approval 1 1 1 5 5 5 15 68.36 65.41 28.22 $810

Complete and submit package 0 10 1 0 50 5 55 68.36 65.41 28.22 $3,412

Subtotal 5 1 12 2 5 60 10 75 -- -- -- $4,549

Total 50 750 $45,486
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6(c) Estimating Agency Burden and Costs 

Exhibit 6.3 presents the total compensation for Agency employees, and Exhibit 6.4 the 

estimated Agency burden hours and costs associated with the information collection activities 

under this ICR. Other direct costs (copying, printing, telephone, and mailing expenses) are also 

included. EPA based its burden estimates on its experience managing SDSI and other voluntary 

programs.

Agency labor costs are calculated based on hourly basic rates for federal employees in the 

Washington-Baltimore area published by the Office of Personnel Management for 2015, 

effective January 2015. The average hourly labor rate for managerial staff is estimated as the 

rate for a GS-13 Step 5 employee and for technical staff as a GS-10 Step 10 employee. It is 

assumed that clerical staff will not be used. These GS-level assumptions are consistent with 

those used in past EPA OPPT ICRs. The hourly labor 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). 

Exhibit 6.3. Total compensation for Agency Employees

Agency 

Employee 

Function

2015 pay grade Hourly

labor rate*

Hourly rate

(hourly labor rate * 

loading factor of 1.6)

Managerial GS-13 Step 5 $49.32 $78.91

Technical GS-10 Step 10 $36.13 $57.81

 *Taken from https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2015/DCB_h.pdf

Exhibit 6.4. Estimated Annual Agency Burden and Costs

Activities Hours per Labor 

Category Labor Cost per Hour Total Cost per Activity Total Hours and Cost

PY

application 

form

EPA 

managerial

EPA 

technical

EPA 

managerial

EPA 

technical

EPA 

managerial

EPA 

technical

Total

Hours per 

Activity

Total Cost 

per 

Activity

Distribute 

forms 7 23 $78.91 $57.81 $552 $1,330 30 $1,882

Answer 

questions 7 23 $78.91 $57.81 $552 $1,330 30 $1,882

Record / 

enter forms 10 30 $78.91 $57.81 $789 $1,734 40 $2,523

Verify 

information; 

Make awards 

selection

12 38 $78.91 $57.81 $947 $2,197 50 $3,144

Notify 

applicants of 

decision

3 9 $78.91 $57.81 $237 $520 12 $757
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6(d) Estimating the Respondent Universe and Total Burden and Costs

EPA estimates that 50 applications will be submitted each year over the three-year life of 

the clearance. This estimate is based on the 2015 PY Awards cycle, which had 35 applications. 

EPA expects a higher number of applications in subsequent years as more companies partner 

with the Safer Choice Program. Furthermore, due to the nature of the PY awards and the 

demographic of interested parties, EPA estimates that about nearly half of participating 

companies will be product formulators/manufacturers. The total annual burden hours and cost 

associated with this information collection are 750 hours and $45,486, respectively.

6(e) Bottom Line Burden Hours and Cost Tables

a. Respondent Tally

Exhibit 6.5 below summarizes the total annual estimated respondent burden and cost. 

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

this ICR.

Exhibit 6.5. Total Annual Estimated Respondent Burden and Cost Summary

Total # of 

Respondents

Burden Hours Capital and O&M 

Cost

Annual Labor Cost

50 750 $0 $45,486

b. Agency Tally

Exhibit 6.6 below summarizes the total annual estimated agency burden and cost. These 

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

ICR.

Exhibit 6.6. Total Annual Estimated Agency Burden and Cost Summary

Burden Hours Annual Labor Cost

162 $10,188

6(f) Reasons for Change in Burden

There is no change in the total estimated respondent burden compared with that 

identified in the ICR currently approved by OMB.

6(g) Burden Statement

The annual public burden for this collection of information is estimated at 15 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 respond to, a collection of information unless it 

displays a currently valid OMB control number. The OMB control number for this information 
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collection appears above. The OMB control numbers for EPA’s regulations in title 40 of the 

CFR, after appearing in the Federal Register, are listed in 40 CFR part 9 and included on the 

related collection instrument or form, if applicable.

The Agency has established a public docket for this ICR under Docket ID No. EPA-HQOPPT-2014-0736, 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., NW., Washington, DC. The EPA/DC Public Reading Room is open from 

8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays. The telephone number 

for the EPA/DC Public Reading Room is (202) 566-1744, and the telephone number for the 

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

You may submit comments regarding the Agency's need for this information, the 

accuracy of the provided burden estimates and any suggested methods for minimizing 

respondent burden, including the use of automated collection techniques. Submit your 

comments, referencing Docket ID No. EPA-HQ-OPPT-2014-0736 and OMB Control No. 2070-

0184, to (1) EPA online using www.regulations.gov (our preferred method), or by mail to: 

Pollution Prevention and Toxics Docket, Environmental Protection Agency Docket Center 

(EPA/DC), Mailcode: 28221T, 1200 Pennsylvania Ave., NW., Washington, DC 20460, and (2) 

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

Budget (OMB), Attention: Desk Officer for EPA, 725 17th Street, NW, Washington, DC 20503. 
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ATTACHMENTS TO THE SUPPORTING STATEMENT

Attachments to the supporting statement are available in the public docket established for 

this ICR under Docket ID No. EPA-HQ-OPPT-2014-0736. 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. An

authenticated electronic version is available online at the Government

Printing Office's Federal Digital System (FDsys) website.

Attachment B: Safer Choice Partner of the Year Application Form

(EPA Form 9600-04)