Information Collection Request for Partner of the Year 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 Design for the Environment (DfE) Partner**  **of the Year Awards Program I**  **CR Numbers: EP**  **A ICR No. 2450.01**  **OMB Control No. :**  **2070**
**- NEW**  **1(b) Short Characterization / Abstract**  This new information collection request (I CR) addresses the submission of applications to EPA for recognition under the Partner of the Year ( PY ) Awards P rogram. EPA developed The Partner of the Year Awards to recognize DfE stakeholders who have furthered DfE ’s safer chemistry goals through their active and exemplary participation in and promotion of the Program. Making DfE’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 econom y, and creating green jobs, especiall y in the small business sector. The Partner of the Year Awards will be an annual event, with recognition for DfE 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, DfE 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 compan y or organization authorit y (e.g., Chief Executive Officer, or vice president with responsibility for product formulation).

**2. NEED FOR AND**  **USE OF THE COLLECTION 2(a)**  **Need/Authority for the Collection** A uthority 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 s ource - 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.Information Collection Request for Partner of the Year 2

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. I nvestment anal ys ts and advisers often seek these ty pes of measures in evaluating a co rporation’s sustainability profile and investment worthiness. 1 PY is also an incentive for promoting the 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 verify ing 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 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 Requ**  **ired Prior to ICR Submission to OMB** Prior to submission to OMB, this I CR will be made available to the public for comment through a Federal Register notice. The public will have 60 day s to provide comments. Any comments received will be given consideration when completing the supporting statement that is submitted to OMB. **3(c) Consultations**  Under 5 CFR 1320.8(d)(1) OMB requires agencies to consult with potential I CR respondents and data users about specific aspects of I CRs 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. EPA will ask fo r the following information:

 P rovide y our best estimate regarding how long it would take to complete the application in terms of total hours.

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; 2006Information Collection Request for Partner of the Year 3

 How man y personnel (i.e., clerical, technical, and managerial) would it take for applicants to review the pro gram information, obtain approval from senior management and complete the form.
 In addition, provide EPA with any constructive criticism / comments regarding the application itself, questions posed, instructions, description of the program, etc. **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 DfE

- 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) Sen**  **sitive 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 I nformation Collection,” from June 2, 1999.

**4. THE RESPONDENTS AND THE INFORMATION REQUESTED**  **4(a) Respondents and NAICS Codes**  Under the PY awards pr ogram, EPA seeks applicants from establishments engaged in the production, use, and/or advancement of safer chemicals and who have furthered the goals of DfE 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 requirements covered under this ICR. This list is intended to be illustrative; entities from other industries may elec t to appl y for recognition for PY awards. However, EPA expects that most applications will come from the following industries: NAI CS Code Affected Industry 325510 Paint and Coating Manufacturing 325611 Soap and Other Detergent Manufacturing 325612 Polish and Other Sanitation Good ManufacturingInformation Collection Request for Partner of the Year 4

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 Dry cleaning and Laundry Services **4(b) Information Requested**  Once a prospective organization reviews the PY materials and decides to apply , it should submit a PY Application Form (see Attachment B for complete form). To be eligible for the awards, which will be announced in the fall of 2012, candidates should submit their applications by July 10, 2012. All forms will be available in hard cop y and electronic format. Participants can use the hard copy forms they

receive from EPA by

mail or download PDF vers ions of the forms from the DfE w ebsite at www.epa.gov/dfe

. (i) Data items : The reporting items include:

 Facilit y 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 appl yi ng;
 Des criptions of activities taken to qualify for recognition;

 Signature, name, and title of senior compan y or organization authority (e.g., CEO, or vice president for health and environment). (ii) 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 or vice president for health and environment);

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

 Fax, e

- mail, o r mail the form to EPA;

 Provide relevant documentation to EPA upon request.Information Collection Request for Partner of the Year 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 DfE website;

 Answer questions posed by potential applicants regarding PY recognition;

 Re ceive 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

 Approve candidates for PY recognition based on evaluation criteria 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 DfE w ebsite. 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 candidates have achieved the criteria for recognition. Based on its experience with the Safer Detergents Stewardship In itiative (SDSI ) Awards Program, EPA anticipates needing to exercise this right for no more than one candidate per participant category and has incorpora ted 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 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 ye ars covered b y this ICR.

**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 bothInformation Collection Request for Partner of the Year 6

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 oth ers) 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 Distributo rs, about five local or state governments are likel y 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 p es. EPA used professional judgment to arrive at a burden estimate, as well as its experience with administering the Safer Detergents Stewardship I nitiative (SDSI). Burden hours for the PY application package are for reporting purposes onl y. We expect that for a ty

pical entity , program and application review will take about one hour (technical staff). Obtaining approval, which is likely to involve verify ing 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 EP A 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) Estimati**  **ng Respondent Costs** EPA estimates an average loaded hourl y labor rate (base hourly rate plus fringe and overhead) of $58.22 for managerial staff, $55.43 for technical staff, and $26.03 for clerical staff. These three labor rate estimates are based upon manufacturing industry wage data from Employer Costs for Employee Compensation Supplementary Tables December 2010 (Supplementary Table 2) . In addition, the hourly

labor rates have been rounded, to the nearest cent, for the purposes of this I CR. The derivation of labor rates f or managerial, technical, and clerical staff are shown in Exhibit 6.1. **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** $58.22 $39.27 $18.95 $5.40 $2.03 $4.47 $3.14 $3.91 **Technical** $55.43 $36.93 $18.50 $5.10 $2.00 $4.42 $3.22 $3.77 **Clerical** $26.03 $17.36 $8.67 $1.90 $0.68 $3.16 $0.87 $2.06 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.Information Collection Request for Partner of the Year 7

**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 50**  Review application and program information 0 1 0 0 50 0 50 **58.22 55.43**  **26.03** $2,772 Obtain senior approval 1 1 1 50 50 50 150 **58.22 55.43**  **26.03** $6,984 Complete and submit package 0 10 1 0 500 50 550 **58.22 55.43**  **26.03** $29,017

**Subtotal 50**  **1 12**  **2 50**  **600 100**  **750**

-- -- -- **$38,772 Purchasers and Distributors**  **10** Review application and program information 0 1 0 0 10 0 10 **58.22 55.43**  **26.03** $554 Obtain senior approval 1 1 1 10 10 10 30 **58.22 55.43**  **26.03** $1,397 Complete and submit package 1 0 10 1 0 100 10 110 **58.22 55.43**  **26.03** $5,803

**Subtotal 10**  **1 12**  **2 10**  **120 20**  **150**

-- -- -- **$7,754 Retailers**  **10** Review application and program information 0 1 0 0 10 0 10 **58.22 55.43**  **26.03** $554 Obtain senior approval 1 1 1 10 10 10 30 **58.22 55.43**  **26.03** $1,397 Complete and submit package 0 10 1 0 100 10 110 **58.22 55.43**  **26.03** $5,803

**Subtotal 10**  **1 12**  **2 10**  **120 20**  **150**

-- -- -- **$7,754 Supporters**  **20** Review application and program information 0 1 0 0 20 0 20 **58.22 55.43**  **26.03** $1,109**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**  Obtain senior approval 1 1 1 20 20 20 60 **58.22 55.43**  **26.03** $2,794 Complete and submit package 0 10 1 0 200 20 220 **58.22 55.43**  **26.03** $11,607

**Subtotal 20**  1 12 2 **20 240**  **40 300**  $15,509 **Innovators 20**  Review application and program information 0 1 0 0 20 0 20 **58.22 55.43**  **26.03** $1,109 Obtain senior approval 1 1 1 20 20 20 60 **58.22 55.43**  **26.03** $2,794 Complete and submit package 0 10 1 0 200 20 220 **58.22 55.43**  **26.03** $11,607

**Subtotal 20**  **1 12**  **2 20**  **240 40**  **300**

-- -- -- **$15,509 Total**  **110 1650**  **$69,790**Information Collection Request for Partner of the Year 8

**6(c) Estimating Agency Burden and Costs**  Exhibit 6.3 presents the total compensation for Agency employ ees, 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 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 employ ees in the Washington

- Baltimore area published b y the Office of Personnel Management for 2011, frozen at January

2010 levels. 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 I CRs. 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 (I CRs) (OPPE, 1992, page 30, footn ote 9). **Exhibit 6.3.** Total comp ensation for Agency Employ ees **Agency Employee**  **Function 2011 pay grade**  **Hourly rate**  Managerial GS

- 13 Step 5 $48.35
Technical GS

- 10 Step 10 $35.32

Taken from http://www.opm.gov/oca/11tables/pdf/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 $48.35 $35.52 $338 $817 30 $1,155 Answer questions 7 23 $48.35 $35.52 $338 $817 30 $1,155 Record / enter forms 10 30 $48.35 $35.52 $484 $1,066 40 $1,549 Verify information; Make awards selection 12 38 48.35 35.52 $580 $1,350 50 $1,930 Notify applicants of decision 3 9 48.35 35.52 $145 $320 12 $561Information Collection Request for Partner of the Year 9

**6(d) Estimating the Respondent**  **Universe and Total Burden and Costs** EPA estimates that 110 applications will be submitted each ye ar over the three

- ye ar life of the clearance. 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 1,650 hour s and $69,790, 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 an y 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**  **Average Burden Hours Capital and O&M**  **Cost Annual Labor Cost** 
110 1,650 $0 $ 69,790 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 y ear over the three y ears covered by this ICR. **Exhibit 6.6 . Total Annual Estimated Agency Burden and Cost Summary** 

**Burden Hours Annual Labor Cost**  162 $ 6,350 **6(f) Reasons for Change in Burden**  Since this is a new I CR, change in respondent burden is not applicable. **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 ag ency may not conduct or sponsor, 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 informationInformation Collection Request for Partner of the Year 10

collection appears above. The OMB control number s 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. To comment on the Agency ’s need for this information, the accura cy 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 I CR und er Docket ID No. EPA

- HQ

- OPPT

- 2011

- 0858 . The docket i s available for public 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 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. An electronic version of the public docket is available through the Federal Docket Management S ys tem (FDMS) at www.regulations.gov . Use FDMS 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 . Once in the sy stem, select “search,” then key in the docket ID number identified above. Also, y ou can send comments to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Office for EPA. Please include the E PA Docket ID No. EPA

- HQ

- OPPT

- 2011

- 0858 and OMB control number 2070

- NEW in any

correspondence.Information Collection Request for Partner of the Year 11 **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

- 20 1 1

- 0858 . 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**  . Al so available

at online at the US House of Representatives’ Office of the Law Revision Counsel’s US Code website **Attachment B: Design for the Environment Safer Product Labeling Program** 

**Partner of the Year Application Form**