MEMORANDUM 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

SUBJECT: Response to Comments Received on the New ICR entitled "Assessment of 

Environmental Performance Standards and Ecolabels for Federal Procurement" (EPA-HQOPPT-2014-0838) -· 

FROM: David Widawsky, Director ~ V L 'v X 6{1- 1 (' Chemistry, Economics and Sustai~le Strate~ision 

TO: Angela Hofmann, Director 

Regulatory Coordination Staff 

Background 

On March 19, 2015, EPA published a Notice in the Federal Register (80 FR 06275) titled 

"Agency Information Collection Activities; Proposals, Submissions, and Approvals: Assessment 

of Environmental Performance Standards and Ecolabels for Federal Procurement; EPA ICR 

No. 2516.01, OMB Control No. 2070-new." (See 

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OPPT -2014-0838-0001 ). This 

Notice refers to EPA's intention to request new Office of Management and Budget (OMB) 

clearance of an information collection related to the assessment of environmental performance 

standards and ecolabels for Federal procurement. 

In addition to public notice and comment requirement that the above Notice initiates, OMB 

regulations at 5 CFR 1320.8(d)(l)) require agencies to consult with potential respondents and 

data users about specific aspects of an information collection request (ICR) before submitting it 

to OMB for review and approval. 

EPA solicited input on the following questions: 

Are the data that EPA seeks under this ICR available from any public source, or already 

collected by another EPA office or by another agency? If so, where can the data be found? 

Is it clear what is required for data submission? If not, are there any suggestions for clarifying 

instructions? 

Would you be interested in an electronic/data submission option? What type of alternative 

would you be most likely to utilize - web form, diskette, CD-ROM? 

For electronic submission, how should signature requirements be handled - Private Key 

Infrastructure, PINS and passwords, signed paper cover sheet? 

Internet Address (URL) • http:/twww.epa.gov 

Rec:ycl.c1/Rec:yclable • Printed wkh Vegetable 01 Based Inks en Recycled Paper (Minimum 25% Postconsumer) 
Do you agree with EPA's estimated burden and costs (the ICR addresses only the costs 

associated with paperwork)? Are the Bureau of Labor Statistics (BLS) labor rates accurate? If 

you have any reason to consider the BLS labor rates as used by EPA inaccurate or inappropriate, 

explain your rationale. 

Public Comments 

All but two of the comments received via the Federal Docket Management System and via email 

correspondence were related to other questions posed in the Federal Register Notice, not related 

to the ICR (e.g., panel membership and qualifications for the Stakeholder Panels and Governance 

Committee, or to volunteer particular standards for assessment). 

Comments received from NSF International and the Business and Institutional Furniture 

Manufacturers Association (BIFMA) spoke specifically to the Information Collection Request 

and provided suggestions. The comments were supportive of our information collection 

mechanisms, indicating neither that NSF International nor BIFMA were aware of any previous 

attempt to collect the requested data and that the information was not currently being collected 

by any other agencies. Additionally, BIFMA noted that the information sought was critical to 

effectively determining how well existing standards and ecolabels would measure up to EPA 

guidance. In their comment, NSF International noted the clarity of the information request, and 

was supportive of our approach to collect submissions under the ICR via web submission form, 

and noted a preference for a PIN and password infrastructure for electronic submission. BTFMA 

indicated a preference for electronic submission of materials as a way to stream! ine information 

collection, and expressed doubt that a PfN and password system were necessary. Both BIFMA 

and NSF International agreed with EPA's cost estimates and the Bureau of Labor Statistics labor 

rates that were presented. 

Response to Comments 

EPA would like to thank the entities that submitted comments for this ICR. EPA has carefully 

reviewed the comments submitted and believes that changes to the ICR narrative are not 

warranted for the following reasons: 

The burden estimates presented in the ICR supporting statement are reasonable estimates for the 

average submitters and EPA recognizes that some respondents may have a higher or lower 

burden. It is clear from the comments received that this effort is not duplicative of any other 

agency efforts. 

The mechanisms for information collection used under the Assessment of Environmental 

Performance Standards and Ecolabels for Federal Procurement are in line with the comments 

received, and will not require any substantive changes to the ICR.