1 **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**  **Pa rtner**  **of the Year Awards Program I**  **CR Numbers: EP**  **A ICR No. 2**  **450 .0**  **2 OMB Control No.**  **: 2070** 
**- 0184**  **1(b) Short Characterization / Abstract**  This information collection request (ICR) renewal addresses the submission of applications to EP A’s Safer Choice Program for recognition under the Partner of the Year ( P Y) 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 Safe r 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 P rogram. 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, especiall y in the small business sector. EPA hosted its inaugural PY Awards in June 2015 and rec ognized 21 organizations in five categories. Furthermore, Executive Order 13693, issued February

19, 2015, recognizes the Safer Choice program as one of the way s 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 - governme ntal 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 crite ria , 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 b y a comp an y or organization authorit y (e.g., CEO, vice president for governmental affairs, division head, or other authorized signatory).2

**2. NEED FOR AND USE OF THE COLLECTION**  **2(a) Need/Authority for the Collection**  Authority for PY derives from s ection 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 te chniques by businesses. Also, s ection 6604(b)(13) directs EPA to establish an annual awards program to recognize a compan y 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 b y providing the means to, and an objective measure of, environmental stewardship. Investment anal ys ts and advisers often seek these ty pes of measures in evaluating a corporation’s sustainability profile and investment worthiness. 1 PY is also an in centive for promot ing th e greater use of sa fer 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 informati on 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 currentl y being collected b y EPA, other federal or state agencies, or proprietary sources. The information collected by the PY Awards Program is unique and is not duplicative of prev ious information collection requests. EPA also checked with potential respondents (e.g., trade associations ) to confirm that the information being collected b y 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 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 conside ration when completing the supporting statement that is submitted to OMB.

1 “ Gr een 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; 20063

**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 bef ore 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 formall y 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 I CR 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 b y 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 , religiou s 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 Sy stem (NAICS) codes and associated industries that may be affected by

information collection requi rements covered under this ICR. This list is intended to be illustrative; entities from other industries may elect to appl y for recognition for PY awards . However, EPA expects that most applications will come from the following industries: NAI CS Code Af

fected Industry 325510 Paint and Coating Manufacturing 325611 Soap and Other Detergent Manufacturing4

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 cop y forms they receive from EPA b y mail or download PDF vers ions of the forms from the Safer Choice w ebsi te 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 prim ary contact person;
 Recognition category

(or categories) for which the candidate is appl yi ng;
 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 compan y 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 appl y 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 compan y 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.5

**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 que stions posed by potential applicants regarding PY recognition;

 Receive the completed forms, review for completeness and place an y necessary follow

- up calls;

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

 Ap prove 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 cop y 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 anal yz ing the information associated with this I CR, EPA will use a telephone sy stem, personal computers, and applicable database software. EPA will ensure the accuracy and completeness of collected information by reserving the right to request relevant documentation at any time to confirm that c andidates 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 s ection 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 benefi ts 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 ye ars covered b y this ICR.6

**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 t ypes of participants. The expected participant categories for PY are as follows: (1) Formulators/Product Manufacturers (of both con sumer 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 ty pes. 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 applic ation package are for reporting purposes only

. EPA expect s that for a t ypical 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 E PA 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) Estimat**  **ing Respondent Costs** EPA estimates an average loaded hourl y 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 I CR. The derivati on of labor rates for managerial, technical, and clerical staff are shown in Exhibit 6.1.7

**Exhibit 6.1. Derivation of Total Compensation**

**Total com** **pensation 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 $1.9 6 $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 ye ars covered under this I CR assuming 15 hours for all participant categories. No capital or operations and management costs are incurred b y respondents under this ICR, with the possible exception of postage and photocopy costs.8

**Exhibit 6.2. Estimated Annual Burden and Costs to Respondents Type of**  **Affected Public**  **Collection activity Estimated**  **# of applicants**  **Estimated response**

**tim e (hours)**  **Total burden (hours) Hourly labor cost** * **Total cost Mgr.**  **Tech. Cler.**  **Mgr. Tech.**  **Cler. Total**  **Mgr. Tech.**  **Cler. P** **r i** **v a** **t e** **S e** **c t** **o r**  **Formulators/Product Manufacturers**  **2 2**  Review application and program information 0 1 0 0 2 2 0 22 **68.36 65.41**  **28.22** $ 1, 439 Obtain senior approval 1 1 1 22 2 2 2 2 66 **68.36 65.41**  **28.22** $ 3, 564 Complete and submit package 0 10 1 0 22 0 2 2 2 42 **68.36 65.41**  **28.22** $ 15, 011

**Subtotal 2**  **2 1**  **12 2**  **2 2**  **264 46**  **330**

-- -- -- **$ 2**  **0,01 4**  **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 package 1 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** **P r** **i v** **a t** **e S** **e c** **t o** **r a** **n d** **L o** **c a** **l /** **S t** **a t** **e G** **o v** **e r** **n m** **e n** **t s**  **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 7**  **50 $**  **4 5,486** 9

**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 I CR. Other direct costs (copying, printing, telephone, and maili ng 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 b y 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 employ ee . It is assumed that clerical staff will not be used. These GS

- level assumptions are consistent with those used in past EPA OPPT I CRs. The hourl y labor rates were multiplied by an assumed loading factor of 1.6 to reflect Federal fringe benefits and over head. 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 comp ensation for Agency Employees **Agency Employee**  **Function 201**  **5 pay grade**  **Hourly l**  **abor 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 aw ards 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 $75710

**6(d) Estimating the Respondent Universe and Total Burden and Costs**  EPA estimates that 50 applications will be submitted each year over the three

- ye ar 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 y ears as more companies partner w ith the Safer Choice Program. Furthermore, due to the nature of the PY awards and the demographic of interested parties, EPA estimates that about nearl y 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 , respectivel y. **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 ye ar over the three ye ars covered b y this I CR. **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

Tall y Exhibit 6.6 below summarizes the total annual estimated agency burden and cost. These estimates represent the average burden in an y given year over the three years covered by this ICR. **Exhibit 6.6 . Total Annual Estimated Agency Burden and Cost Summary** 

**Burden Hour s**  **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 I CR currently approved b y 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 spons or, and a person is not required to respond to, a collection of information unless it display s a currently

valid OMB control number. The OMB control number for this information11

collection appears above. The OMB control numbers for EPA’s regulations in ti tle 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 I CR under Docket ID No. EPA

- HQ

OPPT

- 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, 13 01 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 holiday s. The telephone number for the EPA/DC Public Reading Room is (202) 566

- 1744, and the telephone number for the Pollution Prevention and Toxics Docket is (202) 566

- 0280. You may submit comments regarding the Agency's need for this information, the accuracy of the provided burden estimates and any suggested methods for minimizing respondent burden, in cluding 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 b y 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 b y 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 20503.12

**ATTACHMENTS TO THE SUPPORTING STATEMENT** Attachments to the supporting statement are available in the public docket established for this I CR under D ocket ID No. EPA

- HQ

- OPPT

- 201 4

- 0 736 . 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 electro nic version is available online at the Government Printing Office's Federal Digital Sy stem (FDs y s) website. **Attachment B: Safer Choice**  **Pa rtner**  **of the Year Application Form**

**(EPA Form 9 6**  **00**
**- 04**  **)**