­

The
SunWise
School
Program
ICR
#
1904.01
May
31,
2000
U.
S.
Environmental
Protection
Agency
Office
of
Air
and
Radiation
Part
A
of
the
Supporting
Statement
1.
Identification
of
the
Information
Collection
1(
a)
Title
of
Information
Request
The
title
of
this
Information
Collection
Request
(
ICR)
is
The
SunWise
School
Program
(
ICR#
1904.01).

1(
b)
Short
Characterization/
Abstract
The
SunWise
School
Program
was
initiated
in
1998
through
a
statutory
mandate
under
Title
IV
of
the
Clean
Air
Act.
The
long
term
objective
of
the
SunWise
School
Program
is
to
reduce
the
incidence
of,
and
morbidity
and
mortality
from,
skin
cancer,
cataracts,
and
other
UVrelated
health
effects
in
the
United
States.
Short
term
objectives
include:
1)
reducing
the
risk
of
childhood
overexposure
to
the
sun
by
changing
the
knowledge,
attitudes,
and
behaviors
of
elementary
school
children
and
their
care
givers;
and
2)
improving
the
availability
of
accurate,
timely,
and
useful
UV
data
directly
to
schools
and
communities
across
the
United
States.

The
SunWise
Program
builds
on
traditional
health
education
practices
through
the
use
of
existing
curricula,
learning
standards,
scientific
strategies,
and
evaluation
mechanisms.
The
Program
is
a
collaborative
effort
of
schools,
communities,
health
professionals,
educators,
environmental
organizations,
meteorologists,
local
governments,
federal
agencies,
and
others.
Participating
schools
sponsor
classroom
and
school
activities
to
raise
children's
awareness
of
stratospheric
ozone
depletion,
UV
radiation,
the
largely
preventable
health
risks
from
overexposure
to
the
sun,
as
well
as
simple
sun
safety
practices.
All
educators
interested
in
participating
in
this
voluntary
program
are
asked
to
register
using
the
online
form
(
www.
epa.
gov/
sunwise/
join.
html)
or
a
hard
copy
version
distributed
by
EPA.
EPA
will
use
the
information
provided
through
this
registration
to
maintain
a
database
of
participating
schools
and
a
mailing
list
for
information
distribution
purposes.
Participating
schools
receive
a
variety
of
materials,
including
a
classroom
"
Tool
Kit"
of
games,
songs,
puzzles,
story
books,
access
to
the
internet
UV
intensity
mapping/
graphing
tools,
a
cartoon
video
and
more.
The
Tool
Kit
also
includes
sample
sun
safety
policies
and
guidelines
to
help
expand
the
sun
safety
message
beyond
the
classroom.

Teachers
who
sign
up
for
SunWise
are
asked
to
complete
a
survey
at
the
end
of
program
implementation.
Results
of
these
surveys
are
used
to
fine­
tune
existing
SunWise
materials
and
develop
new
ones
that
better
meet
our
participants
needs.
The
teachers
are
also
asked
to
administer
a
brief
survey
to
their
students
before
and
after
program
implementation.
The
results
from
the
student
surveys
are
used
to
evaluate
program
effectiveness
and
also
help
guide
materials
development.
Thirdly,
participating
schools
will
ask
parents
to
complete
a
simple
take­
home
survey
to
identify
sun
safety
knowledge,
given
that
research
indicates
that
child
behaviors
are
based,
in
large
part,
on
modeling
adult
behaviors.
Finally,
school
administrators
will
be
surveyed
to
in
an
effort
to
evaluate
the
practicality
and
success
of
proposed
sun­
protection
policy
changes,
infrastructure
enhancements,
and
the
SunWise
Program
as
a
whole.
All
surveys
will
be
collected
by
the
EPA/
SunWise
Program.
The
surveys
will
be
mailed
out
to
Program
participants
once
they
have
registered.
Survey
responses
are
voluntary
and
anonymous.
The
cost
of
surveying
shall
not
exceed
$
101,000
over
3
years.

2.
Need
for
Use
of
the
Collection
2(
a)
Need/
Authority
For
The
Collection
This
collection
will
be
used
for
program
material
distribution
and
to
determine
program
effectiveness
and
participant
satisfaction.
Surveys
to
be
developed
and
administered
include:

°
Student
survey
to
identify
current
sun
safety
knowledge
and
behaviors
among
students;
°
Parent
survey
to
compare
findings
with
those
of
their
children
as
well
as
to
draw
comparisons
with
the
benchmarks
established
in
other
national
surveys;
°
Teacher
questionnaire
for
measuring
their
receptivity
to
the
educational
component
of
the
Program;
and
°
School
administrator
questionnaire
to
show
receptivity
to
the
SunWise
School
Program
and
its
standards,
such
as
the
educational
component,
proposed
policy
changes,
and
school
practices
with
the
Program.

The
data
will
be
analyzed
and
results
will
indicate
the
Program's
effect
on
participants'
sun­
protection
attitudes
and
behaviors.
Responses
to
the
collection
of
information
are
voluntary.
All
responses
to
the
collection
of
information
remain
anonymous
and
confidential.

The
SunWise
School
Program
recognizes
the
challenge
of
measuring
the
progress
and
evaluating
the
effectiveness
of
an
environmental
and
public
health
education
program
where
the
ultimate
goal
is
to
reduce
risk
and
improve
public
health.
Therefore,
the
continual
and
careful
evaluation
of
program
effectiveness
through
a
variety
of
means,
including
data
from
pre­
and
post­
intervention
surveys,
tracking
and
monitoring
of
classroom
activities
and
school
policies,
and
advisory
board
meetings,
is
necessary
to
monitor
progress
and
refine
the
program.

2(
b)
Practical
Utility/
Users
of
the
Data
EPA/
SunWise
will
use
the
survey
results
to
evaluate
program
effectiveness
and
adapt
as
appropriate
its
messages,
approaches,
and
materials.
Survey
results
will
enable
EPA/
SunWise
to
better
meet
the
needs
of
it's
teacher
and
student
participants,
with
the
long
range
goal
of
reducing
the
incidence
and
effects
of
skin
cancer
and
other
UV­
related
health
problems
among
children
and
adults.

3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
3(
a)
Nonduplication
The
information
required
to
complete
the
survey
for
The
SunWise
School
Program
is
not
duplicative
of
information
otherwise
available
to
EPA.
In
the
early
stages
of
the
SunWise
Program's
development
in
1997,
several
searches
for
information
were
completed
in
consult
with
external
stakeholders,
including
representatives
from
the
following
organizations:

American
Academy
of
Dermatology
American
Cancer
Society
Boston
University
Medical
Center
­
Skin
Oncology,
Cancer
Prevention
&
Control
Center
Centers
for
Disease
Control
and
Prevention
National
Association
of
Physicians
for
the
Environment
National
Safety
Council
The
Skin
Cancer
Foundation
Results
from
these
consultations
indicated
that
no
other
formal,
student­
focused,
sun
safety
programs
were
being
implemented
in
the
United
States,
nor
were
surveys
being
conducted
on
attitudes
and
practices
of
children
relating
to
sun
exposure.
There
was,
however,
a
school
administrators
survey
that
was
administered
by
the
AMC
Cancer
Center
in
1998.
The
AMC
Cancer
Center
survey
is
not
duplicative
of
the
survey
we
are
proposing
in
that
our
survey
has
a
distinct
sampling
frame
(
SunWise
participants
only)
and
will
monitor
changes
over
time.

3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
Official
notice
of
this
proposed
collection
appeared
int
the
Federal
Register/
Vol.
64,
No.
244/
Tuesday,
December
21,
1999.

3(
c)
Consultations
The
following
professionals
were
consulted
during
the
development
of
the
four
survey
instruments:

°
Alan
Geller,
Boston
Medical
Center,
Skin
Oncology
Cancer
Prevention
&
Control
Center,
(
617)
638­
7126
°
Dave
Buller,
PhD,
AMC
Cancer
Research
Center,
(
303)
239­
3511
°
Dr.
Barbara
Gilchrest,
Chair,
Department
of
Dermatology,
Boston
University
School
of
Medicine,
(
617)
638­
5538
°
Dr.
Donald
Miller,
Assistant
Professor
of
Epidemiology
and
Health
Policy,
Boston
University
School
of
Medicine,
(
781)
687­
2865
3
(
d)
Effects
of
Less
Frequent
Collection
SunWise
depends
on
registration
information
to
°
maintain
an
accurate
list
of
participants;
and
°
ensure
timely
distribution
of
program
materials
and
program
updates
to
participants.

SunWise
depends
on
survey
responses
to
°
help
guide
program
development;
°
measure
participant
satisfaction
with
the
program;
and
°
elicit
basic
information
on
attitudes
and
practices
of
children
and
their
caregivers
relating
to
sun
exposure.

Conducting
the
surveys
less
frequently
may
slow
down
the
Program's
ability
to
institute
participants'
desired
changes.

3(
e)
General
Guidelines
All
OMB
guidelines
will
be
adhered
to
by
EPA/
SunWise
School
Program.

3(
f)
Confidentiality
Names
of
participating
schools
may
be
made
public.
All
names
of
registered
teachers
and
other
participating
individuals
will
remain
confidential.
All
responses
to
the
collection
of
survey
information
will
remain
anonymous
and
confidential.
A
contractor
will
analyze
survey
results
and,
thereafter,
return
all
completed
surveys
to
EPA.

3(
g)
Sensitive
Questions
The
survey
instruments
of
this
ICR
contain
no
sensitive
questions.

4.
The
Respondents
and
the
Information
Requested
4(
a)
Respondent/
SIC
Codes
Entities
potentially
affected
by
this
action
are
elementary
and
middle
school
students,
parents,
teachers
(
SIC
Div.
I:
Group
8211),
and
school
administrators
(
SIC
Div.
I:
Group
8211).

4(
b)
Information
Requested
The
registration
form
(
Attachment
1)
is
a
simple,
10­
minute
questionnaire
that
asks
teachers
to
provide:
the
name
and
contact
information
of
the
participating
school;
school
composition
(
e.
g.
grade
levels);
and
information
specific
to
the
interest
areas
of
the
registering
teacher.
The
purpose
of
this
form
is
to
ensure
that
EPA
distributes
the
most
relevant
education
materials
to
all
SunWise
participants.

The
survey
instruments
covered
under
this
ICR
are
as
follows:
°
The
SunWise
Student
Survey
(
Attachment
2):
This
survey
will
be
administered
to
participating
students
before
and
after
implementation
of
SunWise
activities.
This
simple,
10­
minute
questionnaire
elicits
basic
information
on
attitudes
and
practices
of
children
relating
to
sun
exposure.
(
2
pages)

°
The
SunWise
Parent
Survey
(
Attachment
3):
Research
indicates
that
child
behaviors
are
based,
in
large
part,
on
modeling
adult
behaviors.
Participating
schools
will
ask
parents
to
complete
a
simple
take­
home
survey
to
identify
sun
safety
knowledge.
(
5
pages)

°
Teacher
Evaluation
of
Classroom
Activities
(
Attachment
4):
Teachers
will
be
asked
to
evaluate
student
receptivity
to
sun
safety
lessons
and
Internet
learning.
Teacher
feedback
about
the
usefulness
of
classroom
and
school
materials
will
be
vital
to
the
refinement
of
sun
safety
education
materials.
(
2
pages)

°
Teacher
and
School
Administrator
Evaluation
of
Infrastructure
Improvements
(
Attachment
5):
Teachers
and
school
administrators
will
be
asked
to
evaluate
the
practicality
and
success
of
proposed
sun­
protection
policy
changes,
infrastructure
enhancements,
and
the
SunWise
Program
as
a
whole.
(
2
pages)

Registration
forms
can
be
submitted
electronically
or
in
hard
copy
form
using
postagepaid
envelopes
provided
by
EPA.
Likewise,
teachers
and
school
administrators
are
given
postagepaid
envelopes
in
which
to
return
their
completed
surveys,
along
with
the
surveys
returned
to
them
by
the
students
and
their
parents.
Neither
the
registration
nor
the
surveys
require
that
respondents
keep
records,
make
photocopies,
or
maintain
files.

1.
The
Information
Collected
5(
a)
Agency
Activities
The
Agency
activities
associated
with
registration
of
participants
done
through
the
SunWise
School
Program
consists
of
the
following:

°
Maintain
participant
database;
°
Maintain
mailing
list
for
information
distribution
purposes.

The
Agency
activities
associated
with
surveying
done
through
the
SunWise
School
Program
consists
of
the
following:

°
Develop
collection
instruments;
°
Answer
respondent
questions;
°
Audit
and/
or
review
data
submissions;
°
Reformat
and
distribute
the
data;
°
Store
the
data.
5(
b)
Collection
Methodology
and
Management
In
collecting
and
analyzing
the
information
associated
with
this
ICR,
EPA
will
use
electronic
and
hard­
copy
registration
forms
and
mailed
surveys,
with
the
possibility
of
electronic
survey
submission
in
the
coming
year.
EPA
will
provide
self­
addressed,
stamped
envelopes
to
respondents.

EPA
will
ensure
the
accuracy
and
completeness
of
collected
information
by
having
all
surveys
reviewed
by
the
contractor.
An
annual
statistical
report
in
consult
with
the
contractor
will
be
developed.

EPA
plans
to
review
the
efficiency
of
using
an
electronic
bulletin
board
or
the
Internet
to
facilitate
the
transfer
of
information
between
EPA
and
potential
or
active
program
participants.

5(
c)
Small
Entity
Flexibility
Not
applicable.

5(
d)
Collection
Schedule
The
SunWise
partner
schools
will
administer
the
student
surveys
two
times
each
school
year
 
once
pre­
program
implementation
and
once
post­
program
implementation
at
the
teacher's
discretion.
The
teacher,
parent,
and
school
administrator
surveys
will
be
administered
once
during
the
school
year.
No
specific
completion
dates
are
given
to
the
respondents.
Respondents
are
requested
to
submit
the
surveys
during
the
school
year
in
which
they
were
administered.
Data
analysis
will
occur
during
the
summer
months,
with
result
available
to
the
public
by
October
of
each
year.
There
is
no
collection
schedule
for
registration.

A.
6
Estimating
the
Burden
and
Cost
of
the
Collection
6(
a)
Estimating
Respondent
Burden
EPA
developed
the
SunWise
Program
Registration
Form
with
the
Agency's
Internet
Support
Team
in
Research
Triangle
Park,
North
Carolina.
Input
from
a
five­
person
focus
group
was
used
to
determine
average
completion
time.
Teachers
are
asked
to
complete
the
registration
form
only
once
during
their
participation
in
the
program
for
a
total
teacher
burden
of
10
minutes.

Annual
estimated
respondent
burden:
Annual
Respondent
Burden­
Registration
Survey
Group
Hour
Burden
Teacher
.17
During
the
development
phase
of
the
surveys,
EPA,
in
consult
with
the
contractor,
conducted
a
pilot
survey
with
no
fewer
than
20
respondents
to
determine
appropriate
content
and
survey
completion
time.
The
student
survey
will
be
administered
two
times
per
year.
Each
survey
will
take
approximately
10
minutes
to
complete,
for
annual
per
student
burden
of
20
minutes.
The
teacher
survey
is
administered
one
time
each
year
and
takes
approximately
30
minutes
to
complete.
The
parent
survey
and
school
administrator
survey
are
also
administered
once
a
year,
and
take
approximately
15
minutes
to
complete.

Annual
estimated
respondent
burden:

Annual
Respondent
Burden­
Surveys
Survey
Group
Hour
Burden
Student
.33
Teacher
.5
Parent
.25
School
Administrator
.25
6(
b)
Estimating
Respondents
Costs
The
Bureau
of
Labor
Statistics
figures
(
http://
stats.
bls.
gov/
news.
release/
ecec.
t02.
htm)
were
used
to
determine
labor
costs
for
these
tables.

Annual
Respondent
Burden
and
Cost­
Registration
Respondent
Group
Hour
Burden
Labor
Cost
Teacher
.17
.17
*
$
36.88
=
$
6.15
Annual
Respondent
Burden
and
Cost­
Surveys
Respondent
Group
Hour
Burden
Labor
Cost
Student
.33
.33
*
0
=
0
Teacher
.5
.5
*
$
36.88
=
$
18.44
Parent
.25
.25
*
$
20.29
=
$
5.73
School
Administrator
.25
.25
*
35.18
=
$
8.80
The
annual
respondent
burden
hours
are
a
total
of
2,167
hours
at
an
annual
cost
of
$
38,454.20.
The
respondents
will
have
no
capital/
startup
or
O&
M
costs.

6(
c)
Estimating
Agency
Burden
and
Cost
Registration
information
collection
will
be
done
primarily
through
a
website
database
feature.
The
start­
up
cost
associated
with
designing
the
registration
web
page
is
estimated
to
be
less
than
$
750.
Operating
and
Maintenance
(
O&
M)
Costs
associated
with
maintenance
of
the
website
are
estimated
to
be
20
hours
per
year
and
will
be
conducted
by
in­
house
EPA
employees.
The
cost
of
this
labor
is
calculated
based
on
a
GS
12
Step
5
pay
level
($
38.25/
hour
using
the
salary
associated
with
this
grade
and
step,
multiplied
by
a
benefits
factor
of
1.616),
making
the
total
annual
cost
$
765.
Finally,
EPA
will
manually
input
all
information
received
via
hard­
copy
registration
form
onto
the
database.
The
costs
of
this
labor
are
estimated
to
be
10
hours
per
year
at
a
GS
5
Step
1
pay
level
($
10.52/
hour
according
to
the
2001
OPM
General
Schedule).
Total
hours
(
10)
multiplied
by
$
10.52
per
hour
amounts
to
a
total
agency
labor
cost
of
$
105.20
per
annum.

Agency
Burden
and
Costs­
Registration
Burden
Hours
Total
Costs
($)

EPA
(
Annual)
30
$
870.20
EPA
(
3­
Year
ICR)
90
$
2,610.60
The
contractor
(
Boston
University
Medical
Center)
will
assist
EPA
in
data
collection
and
analysis.
The
contractor
will
also
provide
technical
support
in
the
development
of
the
surveys.
To
perform
these
functions,
EPA
has
contracted
for
a
total
of
400
professional
hours.
At
an
average
rate
of
$
100
per
hour,
the
total
cost
for
the
contractor
is
$
40,000
annually.
Agency
burden
to
manage
this
contract
is
estimated
at
4
hours/
month
or
48
hours
annually.
The
cost
of
this
labor
will
be
calculated
based
on
a
GS
12
Step
5
pay
level
($
38.25/
hour
using
the
salary
associated
with
this
grade
and
step,
multiplied
by
a
benefits
factor
of
1.616).
Total
hours
(
48)
multiplied
by
$
38.25
per
hour
amounts
to
a
total
agency
labor
cost
of
$
1,836/
per
annum.
Agency
Burden
and
Costs­
Surveying
Burden
Hours
Total
Costs
($)

EPA
(
Annual)
48
$
1,836.00
EPA
(
3­
Year
ICR)
144
$
5,508.00
6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
Costs
(
A)
Number
to
register
(
B)
Total
Hours
(
C)
Rate
per
hour
($)
(
D)
Total
Cost
(
D=
B*
C)

1,000
Teachers
167
$
36.88
$
6,146.70
Total
(
Annual)
167
$
6,146.70
ICR
Total
(
3
years)
500
$
18,440.00
(
A)
Number
to
be
surveyed
(
B)
Total
Hours
(
C)
Rate
per
hour
($)
(
D)
Total
Cost
(
D=
B*
C)

3,000
Students
1,000
0
0
1,000
Teachers
500
$
36.88
$
18,440.00
1,000
Parents
250
$
20.29
$
5,072.50
1,000
School
Administrators
250
$
35.18
$
8,795.0
Total
(
Annual)
2,000
$
32,307.50
ICR
Total
(
3
years)
6,000
$
96,922.50
ICR
Total­
Registration
+
Surveys
(
3
years)
6,500
$
115,362.50
6(
e)
Bottom
Line
Burden
Hours
and
Cost
Tables
Bottom
Line
Burden
and
Costs
(
3­
Year
ICR)

Burden
Hours
Total
Costs
($)
Bottom
Line
Burden
and
Costs
(
3­
Year
ICR)

Students
3,000
0
Teachers
2,000
$
73,760.00
Parents
750
$
15,217.50
School
Administrators
750
$
26,385.00
EPA
234
$
8,118.60
O&
M
Costs
(
EPA
Contractor)

Total
7,934
$
243,481.10
6(
f)
Reasons
for
Change
in
Burden
This
a
new
ICR
submittal.
No
changes
or
modifications
are
requested.

6(
g)
Burden
Statement
Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
disclose,
or
provide
information
to
or
for
a
federal
agency.
This
includes
the
time
needed
to
review
instructions;
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information;
processing
and
maintaining
information,
and
disclosing
and
providing
information;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirement;
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
search
data
sources;
complete
and
review
the
collection
of
information;
and
transmit
or
otherwise
disclose
the
information.
An
agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
currently
valid
OMB
control
number.
The
OMB
control
numbers
for
EPA's
regulations
are
listed
in
40
CFR
Part
9
and
48
CFR
Chapter
15.

Send
comments
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
through
the
use
of
automated
collection
techniques
to
the
Director,
Collection
Strategies
Division,
OIC/
OEI
,
U.
S.
Environmental
Protection
Agency
(
2822),
1200
Pennsylvania
Ave.,
NW,
Washington,
DC
20460;
and
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
DC
20503,
Attention:
Desk
Officer
for
EPA.
Include
the
EPA
ICR
number
and
OMB
control
number
in
any
correspondence.
