MEMORANDUM UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WA S HIN G TON , D .C. 20 460

SUBJECT : Response to Comme nt s Received on the New ICR entitled " Assessment of Environmental Pe r formance Standards and Ecolabels for Federal Pr oc urement " (E PA-HQOPPT

- 2014 -08 38) -· 

### FROM: Da vid Widawsky , 

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# Sustai~le **Strate~ision** TO: Angela Hofmann, Director Regulatory Coordination Staff Background On March 19 , 2015, EPA publi shed a Notice in the Fe deral Register ( 80 FR 06275) titled "A gency Information Collection Activitie s; Propo s als , Submissions , a nd Approvals: Assessment of Env ironmental P erformance Standards and Ecolabe ls for Federal Procurement; EPA ICR No
. 2516.01, OMB Control N o. 2070 -n ew. " (See http: //www. re g ulations.g ov /# !documentDet ail ; D =E PA-H Q-OPPT

- 20 14-08 38 -0001 ). T his No tice refers to EPA's intention to request new Office of Management and Budget (OM B ) clearance of an information co ll ection related to the assessment of environmen tal performanc e s tandard s and ecolabels for Federal procur e ment. In addition to public notic e and comment r e quirement that the above Notice ini tiates , OMB regulations at 5 CF R 1320.8(d) ( l )) requir e agencies to con s ult with potential respondents and data u se rs about s pecific aspect s of an information collectio n request (ICR) before s u bmitt in g it to OMB for revi ew and approval. EPA solicited input on the following que s tions: Are the data that EPA seeks under this ICR availab le from any publi c source, or already co llected b y another EPA office or by another agency ? I f so, where can the data be found? I s it clear what i s requi re d for data s ubmi ss io n ? I f not , are there an y suggest ions for clarifying instructions ? Would yo u be interested in an electronic/ data submission option ? What type of alternative would yo u be most likely to utilize

- web form, di s kette , CD- RO M? Fo r electronic submission , how should signature r eq uirements be handled

- Pri vate Ke y Infrastructure , PINS and password s, signed paper cover sheet?

Internet Address (U RL) • http :/ twww

. epa . gov Rec:yc l .c1/Rec:yc l ab l e • Prin t ed wkh Vegetable 01 Based Inks en Recycled Paper (Minimum 25 % Postconsumer )Do you agree with E P A's e s timated burden and costs ( th e I CR addresses only the costs associated with paperwork )? Are the Bureau of Labor Statistics ( BLS ) labor rates accurate ? If you have any reason to con s ider the BLS labor rate s as used by E PA inaccurate or inappropriate , exp la in yo ur rat io nal e. Public Comments A ll but two of th e co mm e nts r ece ived v ia the Federal D ocket Management Sys te m and v ia em ail correspo nden ce were related to other questions posed in the Fe d e ral Regist er Notic e, not r e lated to the I C R (e.g. , panel membership and qualification s for the Stake holder Panels and Governance Committee , or to volunteer particular standards f o r a ss essment). Comme nt s r ece ive d fro m NSF International and the Bu s in ess and In sti tuti o n a l Furnitur e Manufacturer s Assoc iatio n ( BIFMA ) spoke specifically to the Inf o rmation Co ll ection R equest and provided s uggestion s . T he comment s were suppo rt ive of our information co ll ection mechanisms , indicating neither that NSF International n or BIFMA were aware of any previous attempt to co ll ect the requested data and that th e information was not curre ntl y being coll ec te d by any other age nc ies . Additionally , BI FMA noted that the inf o rm ation so ug ht was cr i t ica l t o effective l y determining how we ll existi ng stan dard s and eco l abe ls would measure up to E P A guidance
. In the ir comme nt , NSF Int ernationa l noted the clarity of the inf o rm at i on requ es t , and was s upporti ve of our approach to collect s ubmi ss io n s und e r th e I C R via web s ubmi ss ion form , a

nd no te d a prefere nc e fo r a PIN and p asswo rd infra s tru c ture for e lec tronic s u bmission. BTFMA indicated a preference for e l ect ron ic s ubmi ssio n of m aterials as a way to s tream ! ine information collectio n , and exp r esse d doubt that a PfN and password system were necessary. Both BI F M A and NSF In ternational agreed w ith EP A ' s cost estim at es and th e Bure au of Lab or S tati s ti cs lab or rates that were presented. Response to Co mments E PA wo uld lik e to thank th e e ntitie s that s ubmitted co mments for thi s I CR. EPA has carefully reviewed the comme nt s subm itt ed and believes that c h a nges to the I C R narrati ve are not warranted for the following reasons: The burden e s tim ates presented in the ICR supporting stateme nt are reasonabl e estim ates for the ave rage s ubmitters and EPA r ecog ni zes that s om e respo ndents ma y have a hi g he r or lowe r burden. It i s clear fr om the commen ts rece ived that this ef fort is not duplicative of an y o th e r a ge nc y effort s . The mec h a ni s m s for information collection u sed und e r t h e Assessment of E nvironme ntal Perfo rman ce S t a ndard s and Ecolabels for Federal Proc urement a r e in line w ith the co mm e nts rec e ived , and w ill not re qu i re any s ub stan ti ve changes to the I C R
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