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SUPPORTING STATEMENT FOR

AN INFORMATION COLLECTION REQUEST (ICR)

1. IDENTIFICATION OF THE INFORMATION COLLECTION

1(a) School Integrated Pest Management Awards Program 

EPA ICR No.: 2531.01 OMB Control No.: 2070-NEW

1(b) Short Characterization

This is new information collection request (ICR) which enables the U.S. Environmental 

Protection Agency to encourage the use of Integrated Pest Management (IPM) as the preferred 

approach to pest control in the nation’s schools. IPM is a smart, sensible, and sustainable 

approach to pest control that emphasizes the remediation of pest conducive conditions. IPM

combines a variety of pest management practices to provide effective, economical pest control 

with the least possible hazard to people, property, and the environment. These practices involve 

exclusion of pests, maintenance of sanitation, and the judicious use of pesticides.

The EPA’s vision is that all students in the U.S. will experience the benefits provided by

an IPM program in their school district. The Agency’s IPM implementation efforts are based on 

a wholesale approach aimed at kindergarten through 12th grade public and Tribal schools. The 

Agency intends to use the information collected through this ICR to encourage school districts to 

implement IPM programs and to recognize those that have attained a notable level of success.

Because IPM implementation occurs along a continuum, the School IPM (SIPM) incentive 

program will recognize each milestone step a school district must take to begin, grow, and 

sustain an IPM program. 

This program has five awards categories - Great Start, Leadership, Excellence, Sustained 

Excellence, and Connector. The first four categories are stepwise levels that are reflective of the

effort, experience, and, ultimately, success that results from implementing EPA-recommended 

IPM tactics that protect human health and the environment. Schools with pest infestations are not 

only exposed to potential harm to health and property, but also to stigmatization. The School 

IPM recognition program will give districts across the nation the opportunity to receive positive 

reinforcement through public recognition of their efforts in implementing pest prevention and 

management strategies.

The School IPM awards program follows the model of the Agency’s Tools for Schools

program that recognized schools for achievements in improving indoor air quality. The highly

successful Tools for Schools program was active for ten years and employed the same tiered 

approach as the School IPM awards program. The awards program will connect the Agency

with school districts to encourage reciprocal learning around IPM.

The awards program, as a whole, provides incentives for sustainable IPM practices in 

schools at the individual for districts as well as individuals, including non-school entities. School 

districts and other participating entities seeking recognition for their IPM programs will need to 

maintain detailed records on a variety of activities and send completed applications to EPA for 

each award to which they aspire. As part of their activities, participants will need to develop an 
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IPM policy and update their IPM plans annually. Applicants will provide information describing 

how they have met the requirements for the award category to which they are applying. There 

are four progressive levels of award for school districts (i.e., Great Start, Leadership, Excellence,

and Sustained Excellence); the Connector award is open to non-school entities and individuals.

Comprehensive school IPM programs create safer and healthier learning environments by

helping to effectively manage pests, reduce children’s unnecessary exposure to pests and 

pesticides, and reduce pest complaints. A relatively small percentage of U.S. K-12 schools 

currently have verifiable IPM programs. The information collected will substantiate the 

implementation of the actions required along the IPM continuum from program initiation to 

robust, sustained implementation. 

The School IPM awards program will initially place more focus on school districts rather 

than individual schools. This is primarily due to the resource requirements to process 

applications from individual schools on a national scale.

2. NEED FOR AND USE OF THE COLLECTION

2(a) Need/Authority for the Collection

Section 13101(b) of the Pollution Prevention Act of 1990, 42 U.S.C. sets forth “the 

national policy of the United States that pollution should be prevented or reduced at the source

whenever feasible.” Section 13102(4) defines source reduction as any practice that “reduces the

amount of any hazardous substance ... released into the environment” and “reduces the hazards 

to public health and the environment associated with the release of such substances.” To 

implement this policy, Section 13103(b)(5) of the Act directs the Administrator of EPA to, 

among other things; “facilitate the adoption of source reduction techniques by business” (see 

Attachment A).

Section 3 of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), 7 U.S.C. 

136a, requires EPA to regulate pesticides to prevent “unreasonable adverse effects” on human 

health and the environment (Attachment B). IPM strategies, such as removing sources of food, 

water, and shelter for pests, reduce pest problems and the unnecessary use of pesticides.

The Food Quality Protection Act (FQPA) of 1996 (7 USC 136r–1) requires the U.S.

Department of Agriculture and EPA to implement programs in research, demonstration, and 

education to support the adoption of IPM, make information on IPM widely available to 

pesticide users, use IPM techniques in carrying out pest management activities, as well as 

promote IPM through procurement, regulatory policies and other activities (Attachment C). The 

School IPM awards program is a non-regulatory approaches to meet the goals of the Pollution 

Prevention Act, FIFRA and FQPA to reduce pesticide risks in non-agricultural settings.

The collection of information that documents and measures applicant accomplishments 

enables EPA to fairly and accurately assess program effectiveness and benefits of awards.

Completed applications, including contact information, are preliminary to EPA’s formal 

recognition. The applications will allow EPA to understand and promote each school district’s
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efforts. In addition, this program will measure individual and collective program progress in 

School IPM implementation.

2(b) Practical Utility/Users of the Data

The information collected by the School IPM awards program is not designed or intended 

to support EPA regulatory decision-making. EPA intends to use the information collected through 

award program applications to:

 Determine applicant eligibility for award recognition

 Identify school districts’ commitment to promoting and implementing IPM practices

 Verify participation in promoting and implementing IPM practices

 Define the existing landscape and implementation status of IPM practices in school

districts nationally

 Measure environmental outcomes

The Agency will use this data to:

 Develop case studies that demonstrate the importance of IPM implementation in school 

districts

 Encourage replication of best practices for adopting, implementing and sustaining 

comprehensive school IPM programs

 Share information on IPM practices that school districts can incorporate into other 

environmental health initiatives (for example, indoor air quality management, asthma 

management, etc.)Provide a better understanding of how schools can effectively

manage environmental issues when faced with budgetary and personnel challenges.

In addition, EPA will analyze the data, to the extent possible, to look for environmental 

trends and highlight program successes by posting information on the Agency’s School IPM 

website.

1

As will be discussed in Section 3(f) of this ICR, the EPA will not publish business

information reported by award program applicants. Data will only be shared publicly in aggregate

form unless otherwise specified and agreed to by the affected school district or awardee.

3. NON-DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION 

CRITERIA

3(a) Non-Duplication

The information to be collected by EPA’s School IPM awards program is unique and is 

not duplicative of other collections. For example, data submitted through the award applications 

are specific to the tasks required to implement an IPM programs in schools. Applicants will not 

be asked to provide information that has been, or is currently being collected by EPA, other

 

1

http://www2.epa.gov/managing-pests-schools (accessed February 12, 2016)
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federal or state agencies, or proprietary sources. While some state and local government agencies 

may require pesticide users to maintain records of pesticide use and IPM, they may not require it 

to be reported. As detailed below, in those instances when a government or private entity collects 

pesticide use and IPM data, it is not of the scope or detail needed to operate the School IPM 

awards program. The EPA consulted with trade associations, nonprofit groups, school districts, 

and other potential participants to confirm that the information being collected by the School 

IPM program does not exist elsewhere.

While developing the IPM measures, the Agency consulted with the Pesticide Program 

Dialogue Committee (PPDC), a Federal Advisory Committee Act advisory board to the 

Agency’s Office of Pesticide Programs. The PPDC is a cross-section of entities with interest in 

pesticide-related matters, including IPM, with representatives from the private sector, 

nongovernmental entities, and the federal government. Within the PPDC, there is a workgroup 

focused on IPM. While EPA did not provide the PPDC with details on the information being

requested from award program applicants, the committee provided advice on long-term program 

goals.

The level of detailed information required for the School IPM award program is not 

available through other organizations. Some states collect pesticide use information. Of these,

California’s data collection is one of the most comprehensive. Even so, its scope is too limited 

for the purpose of this award program because: 1) the reporting is not focused on School IPM; 

and 2) the reporting only applies to California while the Agency’s award program is a 

nationwide program.

State governments’ pest management reports may also not be consistently available due 

to changes in reporting requirements or states’ priorities. An example of a state government 

pesticide data collection program with such limitations is Oregon.2In 2009, Oregon canceled its 

pesticide use reporting requirements because budgetary constraints limited the state’s ability to 

use the data to develop and publish reports.

Some states currently have school IPM requirements based on legislation. These laws

vary in breadth and rigor but all deal with some element of pesticide application in or around 

schools, for example pesticide use notification requirements. Alabama, Louisiana, North 

Carolina, and Texas have regulations on restricted spray zones that impact schools. Some states

require IPM training for those applying pesticides in schools, others define the type of pesticide 

products that can be used in schools, while others require detailed IPM programs for all schools.

The variety of School IPM-related requirements and pesticide data collection mechanisms across 

all states make it difficult for the EPA to access and use these data. Furthermore, the EPA School 

IPM award applications are designed to assess only those activities required to implement an

IPM program in a school district. No governmental entity is collecting the data the Agency needs 

to assess IPM implementation in school districts across the nation. Thus, the EPA believes that 

the information requested through the ICR is not duplicative.

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

Pursuant to 5 CFR 1320.8(d), the EPA will publish a Federal Register Notice announcing

 

2

Pesticide Use Reporting System (PURS)
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this proposed information collection activity and providing a 60-day public comment period. The 

comments received and any additional public comment for this action will be posted in the docket.

3(c) Consultations

During the development of this ICR, the EPA solicited stakeholder input from four 

kindergarten-12th grade school districts, with varied student populations and diverse geographic 

locations, and one non-profit organization. The EPA solicited input on the amount of burden 

hours to complete the application for each award. Participating school districts were selected on 

the basis of their current IPM programs. School districts were provided detailed instructions on 

how to obtain and document the requested information (Attachment D). The input provided by

these entities was used in estimating the respondents’ paperwork burden in Section 6 of this ICR.

In addition to the initial survey for SIPM, following the publication of the first Federal 

Register Notice for this new ICR, EPA staff will contact appropriate stakeholders and ask them 

for their assessment of the regulatory burden estimates expressed by the Agency in this ICR. A 

summary of these consultations will be provided in the supporting statement during the second 

comment period (Attachment E).

3(d) Effects of Less Frequent Collection

The EPA requests that School IPM awardees submit applications at least every two years 

to maintain their award status level. Because of the intended high visibility of the program, less 

frequent resubmission could compromise program integrity. It will also take time for a school 

district to implement their IPM program and report on its results. The Agency believes that the 

two-year timeframe gives schools the flexibility needed to complete a School IPM award 

application and, subsequently begin or further develop their IPM 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). School IPM award program applicants will not need to 

retain records for this program for more than one year. School IPM award program participants 

may resubmit applications every two years to maintain awardee status or to move to the next level 

in the program.

3(f) Confidentiality

EPA has implemented procedures to protect any confidential, trade secret or proprietary

information from disclosure that provide strict instructions regarding access to and contact with 

documents confidential business information (CBI). These procedures comply with EPA’s CBI 

regulations at 40 CFR Part 2, Subpart B. The reporting method and system prevents access to 

and distribution of business information reported by School IPM awardees. Data will only be

shared publicly in aggregate form unless otherwise specified and agreed to by the affected

awardee.

3(g) Sensitive Questions

This information collection activity complies with the provisions of the Privacy Act of 
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1974 and OMB Circular A-108, as amended, “Responsibilities for the Maintenance of Records 

about Individuals by Federal Agencies.” No information of a sensitive or private nature is 

requested in conjunction with this information collection activity. EPA aggregates data before 

sharing it with any party outside of the Agency. School IPM data sharing activities protect an 

organization’s data by presenting them in a general and unidentifiable manner unless otherwise

specified and agreed to by the affected awardee.

4. THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a) Respondents and NAICS codes

School districts, or entities that represent them, are the target applicant pool for the School 

IPM award 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 through the 

School IPM award program. However, EPA expects that most applications will come from public 

kindergarten through 12th grade schools.

NAICS Code Affected Industry

6111 Elementary and Secondary Schools 

6244 Child Day Care Services

56172 Janitorial Services

56173 Landscaping Services

56171 Exterminating and Pest Control Services

5617 Services to Buildings and Dwellings

4(b) Information Requested

School districts seeking recognition in the EPA School IPM award program must fill out one or 

more of five application forms (attachment F). These forms are: 

 The Great Start application form is required for the Great Start award. This award 

recognizes districts that are starting an IPM program.

 The Leadership award application form is required for the Leadership award. This 

award requires a school district to demonstrate how its IPM program was implemented 

to include staff education and the definition of roles and responsibilities.

 The Excellence award application form is required for the Excellence award. This is the 

middle tier of the award program. For this award, applicants must show how employees

have received IPM education, how IPM-related maintenance is performed, and pest 

monitoring is being tracked. 
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 The Sustained Excellence award application form is required for the Sustained 

Excellence award. This level builds on the Excellence award by requiring school 

districts to provide documentation of pest proofing or pest prevention by design. This is 

in addition to documenting how employees are educated on IPM, how pest proofing 

repairs are made, and that pest monitoring is being conducted and tracked.

 The Connector award application is required for the Connector award. This award is 

reserved for the individual or organization that can demonstrate playing a key role in 

implementing an IPM program in a school district.

The time and effort to complete the application form for each type of data collection varies.

For example, the Great Start award only requires applicants to complete a narrative for an IPM 

plan and commit to appointing an IPM coordinator. It does not require the specific measures and 

progress tracking elements present in the Excellence award. Consequently, completing the 

application for the Great Start award is less burdensome than completing the application for the 

Excellence award.

The School IPM information collection instrument assumes that a number of different 

employees or contractors can complete the data collection task for the school district. These 

could include the IPM coordinator, health and safety coordinator, quality assurance specialist, 

pest management professional, campus facility supervisor, custodian, groundskeeper, and food 

service personnel. Each award has a different information collection demand.

The EPA assumes that all of the paperwork burden incurred by individual schools as well 

as by their districts to maintain records and to report (apply) for the incentive program are 

included in the burden estimates provided in the survey responses submitted by the school 

districts. This assumption is based on the fact that many schools are already positioned for such 

school-to-district reporting either because of existing pesticide, IPM, or school environmental 

health reporting requirements. In such cases, information reported by individual schools are 

already compiled and maintained at the district level.

The School IPM awards allow for rolling applications, i.e., applications can be 

submitted at any time during the year. EPA will process each application within 60 days of 

submission. EPA will make award presentations to awardees on a monthly basis as 

applications are approved.

The standard threshold for the four tiered awards that recognize school districts increases 

as an applicant seeks higher levels of recognition. The exception is for the Connector award 

which recognizes an organization or individual for “connecting” school districts to help

implement an IPM program. This award program recognizes the incremental steps it takes to 

implement IPM in a school district. Each award category and its requirements are explained in 

section 4 (c).

4 (c) Incentive program conditions and criteria

The School IPM Awards conditions and criteria, which are summarized 

below, are detailed in Attachment G.
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Great Start Award

The Great Start award is presented to school districts that are in the initial stages of 

implementing an effective IPM program. Applicants must have selected an IPM 

coordinator for the district and created a written IPM policy to receive this award.

Leadership Award

The Leadership award is presented to school districts with a senior-level commitment to 

establish and maintain an IPM program as well as to relate their IPM strategies to the 

framework for effective school IPM programs (i.e., Organize, Assess, Plan, Act, 

Evaluate, and Communicate).

Excellence Award

To merit an Excellence award, applicants need to tell the story of their IPM program in a 

way that demonstrates the program is comprehensive, effective, and moving towards 

being institutionalized as part of a comprehensive environmental health program in the 

district. Specifically, the EPA will look for evidence that: 

 The critical components of the framework for effective school IPM programs (i.e., 

Organize, Assess, Plan, Act, Evaluate, and Communicate) are embodied in the school 

environmental health management program; 

 An established system exists to ensure consistent and sustained action to identify, 

address and prevent pest problems; and

 Evidence that the program is achieving results. 

Sustained Excellence Award

To merit a Sustained Excellence award, applicants must meet the requirements of the 

previous levels of award criteria for at least two years after receiving Excellence award 

recognition. Applicants must demonstrate that its IPM program is sustainable by

providing documentation for pest reduction, health improvements, and financial benefits.

Lastly, Sustained Excellence award applicants must show how the school district 

communicates about its IPM program, both to its internal community (students, parents, 

employees) and to the external community (other districts, surrounding neighborhood, 

and community leaders).

Connector Award

The Connector award is designed to give national recognition to individuals and 

organizations whose actions and initiatives support improved school environmental 

health in their community, region, state, or even nationally, with a special focus on 

actions and initiatives that reflect the spirit of the award. Examples include the following: 

 Development of innovative initiatives, approaches, tools, or resources that have 

contributed to improved school IPM and indoor environments; 
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 Outstanding individuals and groups who have played a coordinating function to bring 

people or IPM programs together to provide mutual assistance and support in school 

IPM implementation; 

 Leadership/mentorship of school or school district’s IPM program; 

 Technical assistance in IPM program implementation;

 Increasing student involvement in IPM, such as integration of science clubs; and 

 Other actions and initiatives that foster interconnectedness and mutual support and 

demonstrate results as part of these efforts.

5. THE INFORMATION COLLECTED – AGENCY ACTIVITIES, COLLECTION 

METHODOLOGY, AND INFORMATION MANAGEMENT

5(a) Agency Activities

Under the SIPM Award program, the EPA engages in the following activities:

Award Application Processing

 Organize applications by region as they are submitted. Track applicants in detailed 

tracking spreadsheet

 Print each application with scoring sheet with evaluation criteria. Create large binder 

for reviewers that contains all the applications and scoring sheets.

 Determine who will be participating on the review panel. Preferably an odd number 

of people. Depending on number of applications, provide lead time of two weeks for 

reviewers to read and score each application.

 Provide regional staff PDF file versions of applications for their review and weigh-in 

as personnel that may have worked with the districts specifically.

 In two weeks, assimilate all score and hold a half day consensus meeting to determine 

what schools districts are worthy of awards. During this meeting each applicant is 

discussed and the strengths and weaknesses of the application documented. This 

information is used in follow up communications (both winners and those not chosen) 

with the applicants for them to improve their next year’s application, if they were not 

chosen.

 Provide a list of selected applicant recommendations to the EPA regional office and 

to headquarters’ senior management for approval.

 Send an announcement email to internal EPA staff about award winning applicants. 

Contact via phone all the applicants being recognized and set up phone meetings with 

those applicants not chosen to share consensus meeting feedback about strengths and 

areas of improvement of the application.

 If there is an event designated for highlighting the award winning school districts and 

invitational travel involved, convey logistics to selected applicants.
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 Using award winning applications, create communications materials to showcase 

these award winning programs. Initiate comprehensive outreach communications plan 

(develop press release, secure Sr. level quote, FB, Twitter postings). If necessary, 

assist applicants with promoting their award using approved EPA messaging about 

the awards program and showcasing school IPM success stories.

In addition to the above listed activities, the Agency also performs an environmental and 

criminal compliance screening to ensure that all members are good actors. The EPA performs this 

task by checking Agency data bases both at headquarters and the regions.

5(b) Collection Methodology and Management

Prospective applicants can obtain the SIPM award application online. In collecting and 

analyzing the information associated with this ICR, the EPA will use a telephone system, 

personal computers, email, and applicable PDF software.

All forms were designed to have a minimum burden on the user. The SIPM award 

applications will be listed on the EPA SIPM website. Once complete, the form is submitted 

online through email to EPA. Application processing can take up to 60 days because of 

compliance screening. The EPA will review each applicant’s environmental compliance history.

To receive recognition, school districts must pass the compliance screening and the criteria set 

forth by the award level. 

5(c) Small Entity Flexibility

The EPA expects to receive applications to the SIPM program from a variety of school 

districts and organizations. Award applications are designed to minimize respondent burden while 

obtaining sufficient and accurate information. The Agency will review members’ applications, 

making allowances on a case-by-case basis for the inapplicability of certain elements and the

applicants’ abilities to provide the information.

Since membership in the SIPM award program is voluntary, applicants may also elect to 

withdraw from the program, at any time, if they do not wish to submit applications needed to 

maintain their award status. The EPA requires that all awardees submit applications every two 

years to maintain recognition status.

5(d) Collection Schedule

Organizations may submit application forms at any time. The SIPM program is a rolling 

admission program. The EPA will approve or reject all applications within 60 days of submission.

School districts may submit the Great Start, Leadership, Excellence, Sustained 

Excellence, and Connector Award at any time of the year. The EPA will seek to hold an 

annual recognition ceremony for awardees at a conference that attracts school districts and 

key stakeholders’ leadership.
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6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION

6(a) Estimating Respondent Burden

Respondent paperwork burden of participating in the SIPM recognition program consists

primarily of the administrative burden associated with applying for the different types of awards.

This involves preparation, submission, and recordkeeping of an application form.

To estimate average annual paperwork burden on respondents, estimated cost per 

respondent is multiplied by the total number of respondents, which are projected based on past 

data. However, since this is a new program there are no past data on the number of applicants to 

develop such projections. Therefore, as a proxy for the School IPM awards program, the Agency

used the data on the number of applicants from its Indoor Air Quality (IAQ) project. As 

discussed in previous sections of this ICR, the Agency modelled the School IPM program after 

the IAQ Tools for Schools program, and believes the initial level of participation may be similar. 

Annual Respondent Numbers (Data from EPA’s IAQ Tools for Schools Awards Program)

Year

Great 

Start 

Applicants

Leadership 

Applicants 

Excellence 

Applicants

Model of 

Sustained 

Applicants

Special 

Achievement 

Applicants*

Total 

Applications 

Received

2009 18 12 13 3 5 51

2008 14 12 6 4 3 39

2007 42 6 8 6 8 70

Annual 

Average 25 10 9 4 5 53

 * IAQ Connector Award started in 2009

Burden estimates were prepared for the average time necessary to perform each activity in 

preparation, submission, and recordkeeping of an application for each award type. Burden estimates 

are based on interviews conducted with representative respondents. Each of the three school 

districts surveyed and the non-profit organization were provided detailed instructions on how to 

obtain each requested burden estimate through both phone conversations and written 

correspondence. Respondents were allowed 30 days to acquire the requested information and 

provide comments and/or suggestions on program improvement when interacting with potential 

school districts.

As shown in Section 6(b), Tables 1 – 5, the total annual burden hours associated with 

applying for an award are 90, 375, 198, 134, and 72 for Great Start Award, Leadership Award, 

Excellence Award, Sustained Excellence Award, and Connector Award, respectively. 

The EPA estimates that, on average, a total of 53 entities per year would participate in the 

SIPM during a three-year period. Since the past data from the EPA’s IAQ project (2000-2010) 

show high variability without an increasing or decreasing trend, and the data for 2010 is not 

complete, the three year average data over 2007-2009 are used as the projected annual number of 
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applicants for the three-year ICR period. For respondents, the EPA estimates an average of 870

hours for all award categories combined, at a total cost of approximately $72,000 annually.

6(b) Estimating Respondent Costs

Consistent with recent ICR submissions, OPP is using labor cost estimates from Agency

economists with respect to wages, benefits and overhead for all labor categories for affected 

industries, state government, and EPA employees. This approach uses a transparent and consistent 

methodology and current publicly available data to provide more accurate estimates and allow easy

replication of the estimates.

Methodology: The calculation of the wage rate uses base wage data for each sector and 

labor type for an Unloaded wage rate (hourly wage rate) and calculates the Loaded wage rate

(unloaded wage rate + benefits) and the Fully loaded wage rate (loaded wage rate + overhead) 

based on that data. Fully loaded wage rates are used to calculate respondent costs. Cost estimates

are based on 2014 wage data.

Unloaded Wage Rate: Wages are estimated for labor types (management, technical, and 

clerical) within applicable sectors. The Agency uses average wage data for the relevant sectors 

available in the National Industry-Specific Occupational Employment and Wage Estimates from 

the Bureau of Labor Statistics (BLS) at http://www.bls.gov/oes/current/oessrci.htm.

Sectors: The specific NAICS code and website for each sector is included in that sector’s 

wage rate table in Attachment H. Within each sector, the wage data are provided by Standard 

Occupational Classification (SOC). The SOC system is used by Federal statistical agencies to 

classify workers into occupational categories for the purpose of collecting, calculating, or 

disseminating data (see http://www.bls.gov/oes/current/oes_stru.htm). The managerial labor rate is 

based on the SOC for management occupations, and the clerical labor rate is based on the SOC for

office and administrative support occupations. The technical labor rate is based on the SOC for

life, physical and social science occupations. For school IPM, the technical rate is based on firstline supervisors/managers of landscaping, lawn service, and grounds keeping workers.

Loaded Wage Rate: Benefits represent approximately 45% of unloaded wage rates, based

on total benefits for all civilian non-farm workers from

http://www.bls.gov/news.release/ecec.t01.htm

Fully Loaded Wage Rate: The loaded wage rate is multiplied by 50% (EPA guidelines 20-

70%) to get overhead costs.

A copy of the formula work sheets used to estimate the labor rates based on 2014 wage 

data and to derive the fully loaded rates and overhead costs for this new ICR are provided in

Attachment H.

Tables 1 - 5 below provide average annual respondent burden and cost estimates by award 

type.
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Table 1. Average Annual Respondent Burden and Cost Estimates - Great Start Award

Collection Activities 

Burden Hours Total

Management Technical Clerical

$86.43 $65.36 $40.14 Hours Costs

per hour per hour per hour

Average time to read instructions 0.2 0.0 0.0 0.2 $14 

Average time to plan activities 0.5 0.0 0.0 0.5 $43 

Average time to gather information 1.0 0.0 0.0 1.0 $86 

Average time to compile and review 1.0 0.0 0.0 1.0 $86 

Average time to complete and submit paperwork 0.8 0.0 0.0 0.8 $65 

Average time to store/maintain data 0.3 0.0 0.0 0.3 $22 

Total per applicant 4 0.0 0.0 4 $317 

# of applicants/year (3-yr avg. over 2007-2009) 25 90

Total annual cost $7,817

Burden hours are from representative school districts that applied for this award in the past.

Wages rates are from BLS for NAICS 999300 – Local Government. May 2014 data.

In Table 1, the cost to apply for the Great Start Award is estimated to be $317 per 

applicant. Based on the data on the number of applicants from the Agency’s Indoor Air Quality 

(IAQ) project, 25 entities are estimated to apply for this award annually for the three-year ICR 

period. The estimated total burden hours are 90 hours and total cost is $7,817. 

Table 2. Average Annual Respondent Burden and Cost Estimates - Leadership Award

Collection Activities 

Burden Hours Total

Management Technical Clerical

$86.43 $65.36 $40.14 Hours Costs

per hour per hour per hour

Average time to read instructions 1.0 0.0 0.0 1.0 $86 

Average time to plan activities 1.5 0.0 0.0 1.5 $130 

Average time to gather information 5.0 0.0 0.0 5.0 $432 

Average time to compile and review 14.0 0.0 0.0 14.0 $1,210 

Average time to complete and submit paperwork 14.0 0.0 0.0 14.0 $1,210 

Average time to store/maintain data 2.0 0.0 0.0 2.0 $173 

Total per applicant 38 0.0 0.0 38 $3,241 

# of applicants/year (3-yr avg. over 2007-2009) 10 375

Total annual cost $32,410

Burden hours are from representative school districts that applied for this award in the past.

Wages rates are from BLS for NAICS 999300 – Local Government. May 2014 data.

In Table 2, the cost to apply for the Leadership Award is estimated to be $3,241 per 

applicant. Based on the data on the number of applicants from the Agency’s Indoor Air Quality 

(IAQ) project, 10 entities are estimated to apply for this award annually for the three-year ICR 

period. The estimated total burden hours are 375 hours and total cost is $32,410.
February 17, 2016

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Table 3. Average Annual Respondent Burden and Cost Estimates - Excellence Award

Collection Activities 

Burden Hours Total

Management Technical Clerical

$86.43 $65.36 $40.14 Hours Costs

per hour per hour per hour

Average time to read instructions 0.5 0.5 $43 

Average time to plan activities 2.0 2.0 4.0 $304 

Average time to gather information 8.0 8.0 16.0 $1,214 

Average time to compile and review 0.5 0.5 $43 

Average time to complete and submit paperwork 0.5 0.5 $43 

Average time to store/maintain data 0.5 0.5 $43 

Total per applicant 12 10 0 22 $1,691 

# of applicants/year (3-yr avg. over 2007-2009) 9 198

Total annual cost $15,216

Burden hours are from representative school districts that applied for this award in the past.

Wages rates are from BLS for NAICS 999300 – Local Government. May 2014 data.

In Table 3, the cost to apply for the Excellence Award is estimated to be $1,691 per 

applicant. Based on the data on the number of applicants from the Agency’s Indoor Air Quality 

(IAQ) project, 9 entities are estimated to apply for this award annually for the three-year ICR 

period. The estimated total burden hours are 198 hours and total cost is $15,216.

Table 4. Average Annual Respondent Burden and Cost Estimates - Sustained Excellence 

Award

Collection Activities 

Burden Hours Total

Management Technical Clerical

$86.43 $65.36 $40.14 Hours Costs

per hour per hour per hour

Average time to read instructions 2.0 0.0 0.0 2.0 $173 

Average time to plan activities 4.0 4.0 0.0 8.0 $607 

Average time to gather information 4.0 4.0 0.0 8.0 $607 

Average time to compile and review 4.0 4.0 0.0 8.0 $607 

Average time to complete and submit paperwork 2.0 2.0 0.0 4.0 $304 

Average time to store/maintain data 1.0 0.0 0.0 1.0 $86 

Total per applicant 17 14 0 31 $2,384 

# of applicants/year (3-yr avg. over 2007-2009) 4 134

Total annual cost $10,332 

Burden hours are from representative school districts that applied for this award in the past.

Wages rates are from BLS for NAICS 999300 – Local Government. May 2014 data.

In Table 4, the cost to apply for the Sustained Excellence Award is estimated to be 

$2,384 per applicant. Based on the data on the number of applicants from the Agency’s Indoor 

Air Quality (IAQ) project, 4 entities are estimated to apply for this award annually for the threeyear ICR period. The estimated total burden hours are 134 hours and total cost is $10,332.
February 17, 2016

Page 15 of 22

Table 5. Average Annual Respondent Burden and Cost Estimates - Connector Award

Collection Activities

Burden Hours Total

Management Technical Clerical

$86.43 $65.36 $40.14 Hours Costs

per hour per hour per hour

Average time to read instructions 0.5 0.5 $43 

Average time to plan activities 0.5 0.5 $43 

Average time to gather information 2.0 2.0 $173 

Average time to compile and review 6.5 6.5 $562 

Average time to complete and submit paperwork 4.5 4.5 $389 

Average time to store/maintain data 0.4 0.4 $35 

Total per applicant 14 0 0 14 $1,245 

# of applicants/year (3-yr avg. over 2007-2009) 5.0 72

Total annual cost $6,223

Burden hours are from representative school districts that applied for this award in the past.

Wages rates are from BLS for NAICS 999300 – Local Government. May 2014 data.

In Table 5, the cost to apply for the Sustained Excellence Award is estimated to be 

$1,245 per applicant. Based on the data on the number of applicants from the Agency’s Indoor 

Air Quality (IAQ) project, 5 entities are estimated to apply for this award annually for the threeyear ICR period. The estimated total burden hours are 72 hours and total cost is $6,223.

6(c) Estimating Agency Burden and Cost

As in the case of respondents, the burden hour data from the EPA’s Indoor Air Quality

program is used to estimate the Agency burden and cost.

To determine Agency costs, the EPA used the Bureau of Labor Statistics estimates of

labor rates for 2014 for the NAICS code for the Federal Executive Branch (NAICS 999100).

The managerial labor rate is based on the SOC (Standard Occupational Classification) for

management occupations; the technical labor rate is based on the SOC for life, physical and 

social science occupations; and the clerical labor rate is based on the SOC for office and 

administrative support occupations. The labor rates are fully loaded and include benefits and 

overhead. Detailed labor costs for agency labor is included in Attachment H.

Tables 6 to 10 summarize the Agency’s burden hours and costs for the different award 

categories.

Table 6. Average Annual Agency Burden and Cost Estimates - Great Start Award

Collection Activities 

Burden Hours Total

Management Technical Clerical

$84.81 $55.73 $31.73 Hours Costs

per hour per hour per hour

Average time to read application and determine if 

applicant met requirements. 0.00 0.13 0.00 0.13 $7 
February 17, 2016

Page 16 of 22

Average time to accept/deny, create a form letter 

and print paper certificate. Division Director 

signature. 0.05 0.08 0.00 0.13 $9 

Average time to create mailing label, track 

applicant in the awards tracking spreadsheet, mail 

certificate and letter to applicant. 0.00 0.03 0.00 0.03 $2 

Total per applicant 0.05 0.25 0.00 0.30 $18 

# of applicants/year (3-yr average over 2007-

2009) 25 7

Total annual cost $448

Burden hours are from the EPA OAR's Indoor Air Quality program.

Wages rates are from BLS for NAICS 999100 – Federal Government. May 2014 data.

In Table 6, the Agency cost per applicant ($18) is estimated first, and multiplied by the 

average annual total number of applicants (25) to obtain an estimate ($448) of the total Agency

cost for the Great Start award. The per-applicant Agency cost is obtained by summing the 

products of wage rates (managerial, technical, and clerical) and the per-applicant burden hours 

for each labor type (0.05 hours of managerial labor, 0.25 hours of technical labor, and zero hours

of clerical labor). Note that the total number of applications reviewed by the Agency includes 

those applications that are not chosen for award as well.

Table 7. Average Annual Agency Burden and Cost Estimates - Leadership Award.

Collection Activities 

Burden Hours Total

Management Technical Clerical

$84.81 $55.73 $31.73 Hours Costs

per hour per hour per hour

Average time to read application and determine if 

applicant met requirements. 0.0 0.17 0.0 0.17 $9 

Average time to accept/deny, create a form letter 

and print paper certificate. Division Director 

signature. 0.05 0.08 0.0 0.13 $9 

Average time to create mailing label, track 

applicant in the awards tracking spreadsheet, mail 

certificate and letter to applicant. 0.0 0.03 0.0 0.03 $2 

Total per applicant 0.05 0.28 0.00 0.33 $20 

# of applicants/year (3-yr average over 2007-2009) 10 3

Total annual cost $200

Burden hours are from the EPA OAR's Indoor Air Quality program.

Wages rates are from BLS for NAICS 999100 – Federal Government. May 2014 data.

In Table 7, the Agency cost per applicant ($20) is estimated first, and multiplied by the 

average annual total number of applicants (10) to obtain an estimate ($200) of the total Agency

cost for the Leadership award. The per-applicant Agency cost is obtained by summing the 

products of wage rates (managerial, technical, and clerical) and the per-applicant burden hours 

for each labor type (0.05 hours of managerial labor, 0.28 hours of technical labor, and zero hours 

of clerical labor). Note that the total number of applications reviewed by the Agency includes 

those applications that are not chosen for award as well.
February 17, 2016

Page 17 of 22

Table 8. Average Annual Agency Burden and Cost Estimates - Excellence Award

Collection Activities 

Burden Hours Total

Management Technical Clerical

$84.81 $55.73 $31.73 Hours Costs

per hour per hour per hour

Organize applications by region as they are submitted. 

Track applicants in detailed tracking spreadsheet. 0.00 0.08 0.00 0.08 $5 

Print each application with scoring sheet with evaluation 

criteria. Create large binder for reviewers that contains all 

the applications and scoring sheets.

0.00 0.08 0.00 0.08 $5 

Determine who will be participating on the review panel. 

Preferably odd number of people. Depending on number of 

applications, provide lead time of two weeks for reviewers 

to read and score each application.

0.25 0.25 0.00 0.50 $35 

Provide regional staff PDFs of their applicants for their 

review and weigh-in as personnel that may have worked 

with districts specifically.

0.00 0.08 0.00 0.08 $5 

In two weeks assimilate all score and hold half day 

consensus meeting to determine what schools districts are 

awards. During this meeting each applicant is discussed 

and strength and weaknesses of the application 

documented. This information is used in follow up 

communications (both winners and those not chosen) with 

the applicants for them to improve their next year’s 

application if they were not chosen this year.

0.00 5.00 0.00 5.00 $279 

Provide a list of selected applicants to recognize; submit to 

EPA regions and senior management for approval. 0.50 0.50 0.00 1.00 $70 

Conduct compliance scans on school districts and 

reconcile any issues that may arise. 0.00 0.50 0.00 0.50 $28 

Send an announcement email to internal EPA staff about 

award winning applicants. Contact via phone all the 

applicants being recognized and set up phone meetings 

with those applicants not chosen to share consensus 

meeting feedback about strengths and areas of 

improvement of the application.

0.00 0.50 0.00 0.50 $28 

If there is an event designated for highlighting the award 

winning school districts and invitational travel involved, 

convey logistics to selected applicants.

0.00 0.17 0.00 0.17 $9 

Using award winning applications create communications 

materials to showcase these award winning programs. 

Initiate comprehensive outreach communications plan. If 

necessary, assist applicants with promoting their award 

using approved EPA messaging about the awards program 

and showcasing school IPM success stories.

0.50 1.00 0.00 1.50 $98 

Total per applicant 1.25 8.17 0.00 9.42 $561 

# of applicants/year (3-yr average over 2007-2009) 9 85

Total annual cost $5,050

Burden hours are from the EPA OAR's Indoor Air Quality program.

Wages rates are from BLS for NAICS 999100 – Federal Government. May 2014 data.
February 17, 2016

Page 18 of 22

In Table 8, the Agency cost per applicant ($561) is estimated first, and multiplied by the 

average annual total number of applicants (9) to obtain an estimate ($5,050) of the total Agency

cost for the Excellence award. The per-applicant Agency cost is obtained by summing the 

products of wage rates (managerial, technical, and clerical) and the per-applicant burden hours 

for each labor type (1.25 hours of managerial labor, 8.17 hours of technical labor, and zero hours 

of clerical labor). Note that the total number of applications reviewed by the Agency includes 

those applications that are not chosen for award as well.

Table 9. Average Annual Agency Burden and Cost Estimates - Sustained Excellence Award

Collection Activities 

Burden Hours Total

Management Technical Clerical

$84.81 $55.73 $31.73 Hours Costs

per hour per hour per hour

Organize applications by region as they are submitted. 

Track applicants in detailed tracking spreadsheet.

0.00 0.08 0.00 0.08 $5 

Print each application with scoring sheet with evaluation 

criteria. Create large binder for reviewers that contains all 

the applications and scoring sheets.

0.00 0.08 0.00 0.08 $5 

Determine who will be participating on the review panel. 

Preferably odd number of people. Depending on number of 

applications, provide lead time of two weeks for reviewers 

to read and score each application.

0.25 0.25 0.00 0.50 $35 

Provide regional staff PDFs of their applicants for their 

review and weigh-in as personnel that may have worked 

with a districts specifically.

0.00 0.08 0.00 0.08 $5 

In two weeks assimilate all score and hold half day 

consensus meeting to determine what schools districts are 

awards. During this meeting each applicant is discussed 

and strength and weaknesses of the application 

documented. This information is used in follow up 

communications (both winners and those not chosen) with 

the applicants for them to improve their next year’s 

application if they were not chosen this year.

0.00 5.00 0.00 5.00 $279 

Provide a list of selected applicants to recognize; submit to 

EPA regions and senior management for approval. 0.50 0.50 0.00 1.00 $70 

Conduct compliance scans on school districts and 

reconcile any issues that may arise.

0.00 0.50 0.00 0.50 $28 

Send an announcement email to internal EPA staff about 

award winning applicants. Contact via phone all the 

applicants being recognized and set up phone meetings 

with those applicants not chosen to share consensus 

meeting feedback about strengths and areas of 

improvement of the application.

0.00 0.50 0.00 0.50 $28 

If there is an event for highlighting the award winning 

school districts and invitational travel involved, convey 

logistics to selected applicants.

0.00 0.17 0.00 0.17 $9 
February 17, 2016

Page 19 of 22

Using award winning applications create communications 

materials to showcase these award winning programs. 

Initiate comprehensive outreach communications plan). If 

necessary, assist applicants with promoting their award 

using approved EPA messaging about the awards program 

and showcasing school IPM success stories.

0.50 1.00 0.00 1.50 $98 

Total per applicant 1.25 8.17 0.00 9.42 $561 

# of applicants/year (3-yr average over 2007-2009) 4 41

Total annual cost $2,431

Burden hours are from the EPA OAR's Indoor Air Quality program.

Wages rates are from BLS for NAICS 999100 – Federal Government. May 2014 data.

In Table 9, the Agency cost per applicant ($561) is estimated first, and multiplied by the 

average annual total number of applicants (4) to obtain an estimate ($2,431) of the total Agency

cost for the Sustained Excellence award. The per-applicant Agency cost is obtained by summing 

the products of wage rates (managerial, technical, and clerical) and the per-applicant burden 

hours for each labor type (1.25 hours of managerial labor, 8.17 hours of technical labor, and zero 

hours of clerical labor). Note that the total number of applications reviewed by the Agency

includes those applications that are not chosen for award as well.

Table 10. Average Annual Agency Burden and Cost Estimates - Connector Award

Collection Activities 

Burden Hours Total

Management Technical Clerical

$84.81 $55.73 $31.73 Hours Costs

per hour per hour per hour

Organize applications by region as they are submitted. 

Track applicants in detailed tracking spreadsheet.

0.00 0.08 0.00 0.08 $5 

Print each application with scoring sheet with evaluation 

criteria. Create large binder for reviewers that contains all 

the applications and scoring sheets.

0.00 0.08 0.00 0.08 $5 

Determine who will be participating on the review panel. 

Preferably odd number of people. Depending on number of 

applications, provide lead time of two weeks for reviewers 

to read and score each application.

0.25 0.25 0.00 0.50 $35 

Provide regional staff PDFs of their applicants for their 

review and weigh-in as personnel that may have worked 

with a districts specifically.

0.00 0.08 0.00 0.08 $5 

In two weeks assimilate all score and hold half day 

consensus meeting to determine what schools districts are 

awards. During this meeting each applicant is discussed 

and strength and weaknesses of the application 

documented. This information is used in follow up

communications (both winners and those not chosen) with 

the applicants for them to improve their next year’s 

application if they were not chosen this year.

0.00 4.50 0.00 4.50 $251 

Provide list of selected applicants to recognize to regions 

and senior management for approval.

0.50 0.50 0.00 1.00 $70 

Conduct compliance scans on school districts and 

reconcile any issues that may arise.

0.00 0.50 0.00 0.50 $28 
February 17, 2016

Page 20 of 22

Send an announcement email to internal EPA staff about 

award winning applicants. Contact via phone all the 

applicants being recognized and set up phone meetings 

with those applicants not chosen to share consensus 

meeting feedback about strengths and areas of 

improvement of the application.

0.00 0.50 0.00 0.50 $28 

If there is an event for highlighting the award winning 

school districts and invitational travel involved, convey 

logistics to selected applicants.

0.00 0.17 0.00 0.17 $9 

Using award winning applications create communications 

materials to showcase these award winning programs. 

Initiate comprehensive outreach communications plan. If 

necessary, assist applicants with promoting their award 

using approved EPA messaging about the awards program 

and showcasing school IPM success stories.

0.50 1.00 0.00 1.50 $98 

Total per applicant 1.25 7.67 0.00 8.92 $533 

# of applicants/year (3-yr average over 2007-2009) 5 45

Total annual cost $2,666

Burden hours are from the EPA OAR's Indoor Air Quality program.

Wages rates are from BLS for NAICS 999100 – Federal Government. May 2014 data.

In Table 10, the Agency cost per applicant ($533) is estimated first, and multiplied by the 

average annual total number of applicants (5) to obtain an estimate ($2,666) of the total Agency

cost for the Connector award. The per-applicant Agency cost is obtained by summing the 

products of wage rates (managerial, technical, and clerical) and the per-applicant burden hours 

for each labor type (1.25 hours of managerial labor, 7.67 hours of technical labor, and zero hours 

of clerical labor). Note that the total number of applications reviewed by the Agency includes 

those applications that are not chosen for award as well.

6(d) Bottom Line Burden Hours and Costs

In this section, the total respondent and Agency burden hours and costs over all award 

types are summarized (Table 11).

Table 11: Total Annual Burden and Cost Summary

Total burden 

hours Total cost

Respondents 870 $ 71,998 

Great Start Award 90 $ 7,817 

Leadership Award 375 $ 32,410 

Excellence Award 198 $ 15,216 

Sustained Excellence Award 134 $ 10,332 

Connector Award 72 $ 6,223 

Agency 181 $ 10,796 

Great Start Award 7 $ 448 

Leadership Award 3 $ 200 

Excellence Award 85 $ 5,050 
February 17, 2016

Page 21 of 22

Sustained Excellence Award 41 $ 2,431 

Connector Award 45 $ 2,666 

Source: Tables 1-10 in this document.

For the respondents across all categories of awards, the total annual cost of applying for 

the School IPM recognition program is estimated at 870 burden hours and $71,998. These costs 

consist of preparing, submitting, and recordkeeping of applications. For the EPA, the total cost of 

administering this recognition program is estimated at 181 hours and $10,796 annually, most of 

which is the cost of reviewing the applications for awards (Table 11).

6(e) Reasons For Changes in Burden

This ICR is being submitted for approval for the first time.

6(f) Burden Statement

The annual respondent burden for this ICR is estimated to average 870 hours. This 

includes average times to carry out activities in Tables 1 – 5 in the section 6(b) above.

The Agency has established a public docket for this ICR under Docket ID No. EPA-HQOPP-2016-0047, which is available for online viewing at http://www.regulations.gov, or in 

person viewing at the EPA Docket Center Public Reading Room, EPA West Building, Room 

3334, 1301 Constitution Avenue, NW, Washington, DC 20004. The EPA Docket Center is open 

from 8:30 a.m. to 4 p.m., Monday through Friday, excluding federal holidays. The docket 

telephone number is (202) 566-1744. 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.

Comments may be submitted to EPA electronically through http://www.regulations.gov

or by mail addressed to Director, Collection Strategies Division, U.S. Environmental Protection 

Agency (2822T), 1200 Pennsylvania Ave., NW, Washington, D.C. 20460. You can also send 

comments to the Office of Information and Regulatory Affairs, of the Office of Management and

Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Office for EPA. Include 

docket ID No. EPA-HQ-OPP-2016-0047 and OMB control number 2070-NEW in any

correspondence.
February 17, 2016

Page 22 of 22

LIST OF ATTACHMENTS

All of the attachments listed below can be found in the docket for this ICR or a hyperlink is 

provided for the source documentation. The docket for the action is accessible electronically

through http://www.regulations.gov using the docket identifier EPA-HQ-OPP-2016-0047.

ATTACHMENT A: 42 UCS 133 Pollution Prevention Act of 1990, available at 

http://www.gpo.gov/fdsys/pkg/USCODE-2009-

title42/pdf/USCODE-2009-title42-chap133.pdf

ATTACHMENT B: 7 USC 136a, Registration of Pesticides, available at 

http://www.gpo.gov/fdsys/pkg/USCODE-2010-title7/pdf/USCODE2010-title7-chap6-subchapII-sec136a.pdf

ATTACHMENT C: 7 USC 136r–1, Integrated Pest Management, available at 

http://www.gpo.gov/fdsys/pkg/USCODE-2010-title7/pdf/USCODE2010-title7- chap6-subchapII-sec136r-1.pdf.

ATTACHMENT D: Stakeholder Survey Letter and Responses – Respondent Burden 

Estimates

ATTACHMENT E: Reserved

ATTACHMENT F: SIPM Award Program Application Guide and Forms

ATTACHMENT G: SIPM Award Program Conditions and Criteria

ATTACHMENT H: Wage Rates Worksheet