PART
A
OF
THE
SUPPORTING
STATEMENT
INFORMATION
COLLECTION
REQUEST
(
EPA
ICR
Number
1885.01)

IAQ
Practices
in
Schools
Survey
U.
S.
Environmental
Protection
Agency
Office
of
Radiation
and
Indoor
Air
Indoor
Environments
Division
A­
1
INFORMATION
COLLECTION
REQUEST
(
EPA
ICR
Number
1885.01)

U.
S.
Environmental
Protection
Agency
Office
of
Radiation
and
Indoor
Air
Indoor
Environments
Division
SECTION
I
 
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1(
a)
Title
of
the
Information
Collection
IAQ
Practices
in
Schools
Survey
1(
b)
Short
Characterization
(
Abstract)

Title
IV
of
the
Superfund
Amendments
and
Reauthorization
Act
of
1986
(
SARA)
gives
the
U.
S.

Environmental
Protection
Agency
(
EPA)
broad
authority
to
research
indoor
air
quality
(
IAQ)

issues,
develop
and
disseminate
information
on
indoor
air
quality,
and
coordinate
efforts
at
the
Federal,
state,
and
local
levels.
As
part
of
this
ongoing
effort,
the
Indoor
Environments
Division
(
IED)
of
EPA's
Office
of
Radiation
and
Indoor
Air
developed
low­
cost
guidance
for
schools,

entitled
IAQ
Tools
for
Schools
(
EPA
402­
K­
95­
001),
to
assist
school
staff
in
preventing,

identifying,
and
solving
indoor
air
quality
problems.
EPA
has
distributed
approximately
30,000
kits
to
date,
over
half
of
them
to
individual
schools.

EPA
proposes
to
collect
data
from
individual
schools
throughout
the
United
States
using
a
fourpage
survey
(
see
Appendix
1).
This
survey
will
be
used
to
gain
information
regarding
the
number
of
schools
that
have
implemented
sound
IAQ­
management
practices,
such
as
those
activities
recommended
in
IAQ
Tools
for
Schools.
These
data
are
essential
for
measuring
the
effectiveness
of
EPA's
outreach
efforts
against
the
Agency's
established
Government
Performance
Results
Act
(
GPRA)
goal.
The
goal
is
to
have
"
15%
of
the
nation's
schools
adopt
good
indoor
air
quality
practices
consistent
with
EPA's
IAQ
Tools
for
Schools."
This
should
result
in
16,650
of
the
nation's
public
and
private
schools
working
towards
achieving
the
implementation
of
sound
IAQ
practices
by
2005.
EPA
intends
to
survey
schools
twice
during
the
period
for
which
this
ICR
is
in
effect
 
once
in
the
first
year
and
again
in
the
third.
Each
survey
distribution
cycle
will
be
conducted
in
the
same
manner,
using
the
same
survey
instrument
and
protocol
and
relying
on
the
same
statistical
assumptions
regarding
response
and
precision.
In
each
cycle,
EPA
will
survey
1,005
schools
selected
randomly
from
a
potential
pool
of
all
public
and
private
schools
operating
in
the
United
States
during
the
school
year
immediately
preceding
the
year
in
which
the
survey
is
conducted.
(
For
example,
schools
surveyed
in
2001
will
be
selected
from
a
registry
of
schools
1Surveys
which
include
a
telephone
component
have
achieved
an
average
response
rate
of
75
percent.
For
example,
response
rates
of
74
percent
were
found
in
election
surveys
conducted
between
1952
and
1992
(
Luevano
94).
Similarly,
response
rates
averaged
76
percent
in
General
Social
Surveys
conducted
between
1975
and
1993
(
Smith
94).
In
addition,
delivery
methods
which
increase
the
perceived
importance
of
the
survey,
such
as
certified
mail,
special
delivery,
or
2­
day
priority
mail,
have
proven
effective
in
increasing
the
overall
response
rate
(
Dillman
96).
The
survey
will
be
distributed
using
an
overnight
delivery
service,
FedEx,
and
will
include
a
follow­
up
telephone
reminder
call.
Consequently,
EPA
anticipates
a
total
response
rate
of
approximately
80
percent.

2See
Table
6.15
3See
Table
6.15
A­
2
operating
in
the
1999­
2000
school
year.)
A
total
of
2,010
schools
will
be
surveyed.
This
sample
size
will
allow
the
Agency
to
develop
the
statistical
data
needed
to
chart
its
progress
towards
meeting
its
GPRA
goal.
By
conducting
two
survey
distribution
cycles,
EPA
will
also
be
able
to
measure
the
effects
of
its
outreach
efforts
to
encourage
schools
to
adopt
sound
IAQ­
management
practices.

EPA
will
initially
mail
a
survey
and
instructions
for
completing
it
to
each
randomly­
selected
school.
Schools
will
be
given
up
to
30
days
to
respond.
At
the
end
of
this
period,
EPA's
contractor
will
contact,
by
telephone,
any
school
that
has
not
responded
by
mail.
School
personnel
will
be
reminded
of
the
survey,
encouraged
to
complete
it,
and
given
the
option
of
responding
by
telephone.
If
a
school
chooses
to
respond
by
telephone,
the
survey
may
be
completed
by
the
appropriate
individual
at
this
time
or
an
appointment
will
be
scheduled
for
EPA
contractor
personnel
to
conduct
the
survey
at
a
more
convenient
time.
Questions
asked
in
the
telephone
interview
will
be
identical
to
those
contained
in
the
original
survey.

EPA
expects
that
approximately
80
percent1
of
the
schools
surveyed
will
submit
a
survey
response;
49.9
percent
of
respondents
will
respond
by
mail
and
50.1
percent
of
respondents
will
provide
their
responses
by
telephone.
All
survey
data,
regardless
of
how
they
are
obtained,
will
be
entered
into
a
database
designed
to
track
the
results.
This
database
will
be
administered
by
EPA
contractor
personnel.

This
survey
effort
is
expected
to
cost
respondents
$
35,8862
and
involve
approximately
1,6123
school
administrators
and
personnel.
In
addition
to
providing
data
on
EPA's
attainment
of
its
GPRA
goal
for
the
implementation
of
sound
IAQ­
management
practices
in
schools,
EPA
will
use
the
data
collected
to
evaluate
the
effectiveness
of
IAQ
Tools
for
Schools
and
other
outreach
efforts
and
to
select
future
initiatives
that
will
further
the
implementation
of
IAQ­
management
practices
in
schools.
If
necessary,
EPA
will
resurvey
schools
in
2005
to
determine
whether
the
A­
3
Agency
has
met
its
GPRA
goal.
It
is
important
to
note
that
the
survey
is
designed
to
measure
the
use
of
sound
IAQ­
management
practices
in
schools,
rather
than
the
indoor
air
quality
of
the
schools
themselves.

SECTION
II
 
NEED
FOR
AND
USE
OF
THE
COLLECTION
2(
a)
Need/
Authority
for
the
Collection
Title
IV
of
the
Superfund
Amendments
and
Reauthorization
Act
of
1986
(
SARA)
gives
EPA
broad
authority
to
research
IAQ
issues,
develop
and
disseminate
information
on
indoor
air
quality,

and
coordinate
IAQ
efforts
at
the
Federal,
state,
and
local
levels.
(
Appendix
2
contains
a
copy
of
the
relevant
sections
of
this
statute.)
The
IAQ
Tools
for
Schools
guidance
was
developed
to
assist
schools
in
identifying,
preventing,
and
solving
IAQ
problems.
Collecting
data
on
the
implementation
of
practices
identified
in
this
guidance
is
necessary
to
determine
the
level
of
activity
taken
by
schools
to
improve
indoor
air
quality.
Survey
results
can
also
be
used
to
better
focus
EPA's
outreach
activities
to
schools.

In
addition,
the
Government
Performance
Results
Act
of
1993
requires
that
Federal
agencies
develop
and
meet
specific
goals
to
measure
the
effectiveness
of
their
programs.
EPA
has
committed
to
a
goal
of
achieving
the
implementation
of
sound
IAQ
practices
in
15
percent,
or
16,650,
of
the
nation's
public
and
private
schools
by
2005.
This
information
request
will
assist
EPA
in
assessing
the
level
of
implementation
around
the
country.
Not
only
will
the
survey
demonstrate
whether
EPA
is
meeting
its
goal,
it
will
also
provide
data
on
what
IAQ
practices
are
being
utilized
and
help
to
identify
activities
recommended
in
IAQ
Tools
for
Schools
which
require
additional
support
or
clarification
from
EPA.

2(
b)
Practical
Utility/
Users
of
the
Data
The
information
collected
in
this
survey
effort
will
be
used
by
EPA
to:
(
1)
assess
the
extent
to
which
schools
are
implementing
sound
IAQ­
management
practices,
such
as
those
described
in
IAQ
Tools
for
Schools;
(
2)
determine
whether
EPA
has
met
its
goals
under
the
GPRA
for
the
implementation
of
sound
IAQ
practices;
and
(
3)
identify
strengths
and
weaknesses
of
the
guidance
in
terms
of
the
ability
of
schools
to
implement
suggested
policies
and
procedures.

Section
4(
b)
i,
Data
Elements,
discusses
the
particular
data
elements
in
the
survey
and
the
purposes
of
these
elements.
A­
4
SECTION
III
 
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
3(
a)
Nonduplication
This
is
the
first
comprehensive
attempt
to
collect
information
about
the
use
of
IAQ­
management
practices
in
our
nation's
schools.
Schools
are
not
required
to
submit
any
information
concerning
the
indoor
air
quality
of
their
facilities
or
any
efforts
to
improve
such
quality
to
EPA
or
any
other
government
agency.
Therefore,
this
first­
time
information
collection
is
non­
duplicative
of
any
past
or
ongoing
EPA
information
collection
effort.

3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
EPA
solicited
public
comments
on
this
Information
Collection
Request
(
ICR)
between
October
20,
2000
and
December
19,
2000.
A
copy
of
the
Federal
Register
document
requesting
comments
is
attached
as
Appendix
3.

3(
c)
Consultations
This
ICR
was
completed
in
consultation
with
the
following
schools,
school
districts,
and
local
health
agencies:

1.
Fort
River
Elementary
School
(
Amherst,
MA)
Russ
Vernon­
Jones,
Principal
(
413)
253­
9731
2.
Walpole
Health
Department
(
Walpole,
MA)
Robin
Chapell,
Chairman
(
508)
660­
7321
3.
Chicopee
Public
Schools
(
Chicopee,
MA)
Jim
Stefanik,
Director
of
Maintenance
(
413)
594­
3417
4.
Portsmouth
School
District
(
Portsmouth,
NH)
Peter
Torrey,
Chairman
(
603)
431­
5080
A­
5
5.
Nashua
Schools
District
(
Nashua,
NH)
Jeannette
Kotopoulis,
Facilities
Director
(
603)
594­
4330
6.
Burlington
Board
of
Health
(
Burlington,
MA)
Todd
Dresser,
Chairman
(
781)
270­
1956
7.
Carlisle
Public
Schools
(
Carlisle,
MA)
David
Flannery,
Facilities
Director
(
978)
369­
6550
8.
Griffin
Memorial
School
(
Litchfield,
NH)
Linda
Scott,
Principal
(
603)
424­
5931
9.
Timberlain
Regional
School
District
(
Plaistow,
NH)
Pete
Taylor,
Facilities
Director
(
603)
382­
6119
3(
d)
Effects
of
Less
Frequent
Collection
The
main
objective
of
the
IAQ
Practices
in
Schools
Survey
is
to
determine
whether
EPA
has
met
its
GPRA
goal
by
2005.
By
surveying
twice
within
a
three­
year
period,
EPA
will
be
able
to
establish
a
baseline
to
use
in
determining
the
percentage
change
made
in
the
implementation
of
IAQ
management
practices
in
schools
between
the
first
and
second
survey
distribution
cycles.
The
survey
schedule
allows
EPA
to
obtain
this
information
well
in
advance
of
2005
and
make
midcourse
corrections
as
necessary
to
ensure
that
the
Agency
meets
its
GPRA
goal.
In
addition,
it
is
unlikely
that
any
school
will
be
surveyed
more
than
once
during
the
period
for
which
this
ICR
will
be
in
effect.
However,
it
is
possible
that,
given
two
random
samples
of
substantially
identical
pools
of
potential
recipients,
there
may
be
some
schools
that
will
be
surveyed
twice.
However,

EPA
considers
this
possibility
to
be
acceptable
due
to
the
need
for
statistically­
valid
data
and
the
relatively
small
burden
the
survey
will
place
on
schools.

3(
e)
General
Guidelines
This
voluntary
information
collection
conforms
to
the
Office
of
Management
and
Budget's
(
OMB)
general
guidelines
on
information
collections.
Under
no
circumstances
will
respondents
be
required
to
take
any
of
the
following
actions:
A­
6

Report
information
to
EPA
more
than
quarterly

Prepare
a
written
response
to
a
collection
of
information
in
fewer
than
30
days
after
receipt
of
a
request

Submit
more
than
an
original
and
two
copies
of
any
document

Retain
records
for
more
than
three
years

Participate
in
a
statistical
study
that
is
not
designed
to
produce
data
that
can
be
generalized
to
the
universe
of
the
study

Utilize
a
statistical
data
classification
that
has
not
been
reviewed
and
approved
by
OMB

Receive
a
pledge
of
confidentiality
that
is
not
supported
by
authority
established
in
statute
or
regulation,
that
is
not
supported
by
disclosure
and
data
security
policies
that
are
consistent
with
the
pledge,
or
which
unnecessarily
impedes
sharing
of
data
with
other
agencies
for
compatible
confidential
use

Submit
proprietary,
trade
secret,
or
other
confidential
information
unless
EPA
can
demonstrate
that
it
has
instituted
procedures
to
protect
the
information's
confidentiality
to
the
extent
permitted
by
law
3(
f)
Confidentiality
EPA
does
not
expect
to
receive
confidential
information
from
the
schools
voluntarily
participating
in
the
IAQ
Practices
in
Schools
Survey.

3(
g)
Sensitive
Questions
The
IAQ
Practices
in
Schools
Survey
contains
no
sensitive
questions.
A­
7
SECTION
IV
­­
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
4(
a)
Respondents/
SIC
Codes
The
IAQ
Practices
in
Schools
Survey
will
be
sent
to
the
school
principal.
EPA
expects
that
the
survey
might
be
completed
by
a
school's
administrator
or
its
IAQ
Coordinator.
From
past
experience,
individuals
who
are
most
likely
to
be
named
IAQ
Coordinators
include
school
principals,
building
superintendents/
facility
managers,
school
nurses,
and
teachers.
All
of
these
professions
fall
into
the
following
SIC
code:

8211
Elementary
and
Secondary
Schools
4(
b)
Information
Requested
4(
b)
i
Data
Elements
The
IAQ
Practices
in
Schools
Survey
will
be
sent
to
schools
that
have
been
randomly
selected
from
a
potential
pool
of
all
public
and
private
schools
operating
in
the
United
States
during
the
school
year
immediately
preceding
that
in
which
the
survey
is
conducted.
(
For
example,
schools
surveyed
in
2001
will
be
selected
from
a
registry
of
schools
operating
during
the
1999­
2000
school
year.)
A
copy
of
the
survey
and
instructions
for
completing
it
are
attached
to
this
ICR
as
Appendix
1
of
the
Supporting
Statement.

The
survey
will
request
the
following
information
from
respondents:

Reporting
Items

General
Information:
These
questions
seek
general
information
about
the
respondents
and
the
schools
for
which
they
are
responsible.
Included
in
this
section
are
questions
concerning
the
type
of
school
(
public/
private),
the
grade
level
(
elementary/
secondary),
the
size
of
the
student
and
faculty
populations,
the
size
of
the
physical
plant,
the
type
of
heating,
ventilation,
and
air
conditioning
system
used,
and
the
outdoor
ventilation
rate
of
the
school.
These
data
are
important
to
identifying
trends
in
the
types
of
schools
utilizing
good
IAQ
practices.


Implementation
Activities:
These
questions
request
information
about
the
respondents'
IAQ­
management
practices,
including
the
adoption
of
specific
practices
recommended
in
IAQ
Tools
for
Schools
or
other
EPA
IAQ
guidance.
A­
8

Barriers
to
Implementing
IAQ­
management
Practices:
This
question
identifies
potential
barriers
to
implementing
good
IAQ­
management
practices
and
asks
the
respondents
if
they
encountered
any
of
them
in
their
efforts
to
implement
the
activities
suggested
in
the
guidance.


Effects
of
IAQ­
management
Practices:
This
question
asks
respondents
to
identify
any
positive
effects,
such
as
lower
absenteeism
or
fewer
asthma
episodes,
they
may
have
observed
as
a
result
of
their
implementation
of
IAQ­
management
practices.

There
are
no
record­
keeping
items
specifically
required
by
this
survey.
While
maintaining
records
of
repairs,
upgrades,
inspections,
and
the
like
is
considered
a
sound
IAQ­
management
practice,

EPA
does
not
require
schools
to
maintain
these
records.

4(
b)
ii
Respondent
Activities
Schools
who
elect
to
participate
in
EPA's
IAQ
Practices
in
Schools
Survey
will
perform
the
following
tasks:


Review
Survey
Instructions

Compile
Survey
Information

Complete
Survey

Mail
Survey
to
EPA
These
activities
represent
a
voluntary
information
collection
for
each
school
and
are
not
customary
business
practices
of
the
respondents.

SECTION
V
 
THE
INFORMATION
COLLECTED
 
AGENCY
ACTIVITIES,

COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
5(
a)
Agency
Activities
Agency
activities
associated
with
the
IAQ
Practices
in
Schools
Survey
include
the
following:


Develop
Survey
Form

Pretest
Survey
Form

Develop
IAQ
Practices
in
Schools
Database

Identify
Target
Schools
(
i.
e.,
select
random
sample)


Distribute
Survey
to
Target
Schools

Collect
Information
from
Respondents
via
Mail
or
Telephone
A­
9

Review
Information
Collected
and
Complete
Data
Entry

Analyze
Results

Prepare
Findings
5(
b)
Collection
Methodology
and
Management
The
IAQ
Practices
in
Schools
Survey
is
a
four­
page
survey
which
elicits
predominantly
multiple
choice
responses.
The
survey
was
peer­
reviewed
by
staff
of
EPA's
IED
and
EPA
Regional
offices
to
ensure
that
the
questions
asked
will
reveal
sufficient
information
to
adequately
evaluate
the
IAQ
practices
implemented
in
schools
and
to
ensure
that
the
questions
do
not
collect
redundant
information.
In
addition,
the
survey
instrument
was
pretested
on
behalf
of
nine
schools
by
school
principals,
facility
directors,
building
engineers,
and
health
officials
(
see
Section
3(
c)).

This
pretest
was
conducted
to
ensure
that
the
questions
asked
are
clear
and
to
obtain
an
estimate
of
the
burden
of
response.

In
collecting
and
analyzing
the
information
associated
with
this
ICR,
EPA
will
use
a
telephone
system,
personal
computers,
and
applicable
database
software.
EPA
will
ensure
the
accuracy
and
completeness
of
collected
information
by
reviewing
each
submission.
Each
survey
form
will
be
assigned
a
unique
identifier
to
facilitate
the
tracking
of
survey
responses
within
the
project
database.
EPA
will
enter
the
survey
results
into
a
Microsoft
Access
database
and
aggregate
the
data
to
monitor
the
implementation
of
sound
IAQ
practices
in
schools.
A
double­
entry
protocol
will
be
observed
throughout
data
entry
to
ensure
an
accuracy
rate
of
at
least
99
percent.
Under
this
protocol,
each
survey
form
will
be
entered
into
the
database
twice,
after
which
a
computer
program
designed
to
identify
variances
in
the
data
entered
will
be
run.
Following
data
entry,
a
final
review
of
survey
responses
will
be
performed
to
identify
numerical
outliers
in
individual
responses
and
to
ensure
file
completeness.
Blank
responses
and
outliers
will
be
checked
against
the
hard
copies
of
the
survey.

The
results
of
each
survey
distribution
cycle
will
be
summarized
and
made
available
to
the
U.
S.
Congress
during
EPA's
reporting
of
its
GPRA
goals.
Additionally,
IED
will
report
to
the
Information
Strategies
Branch
on
the
results
of
the
survey
process
and,
upon
request,
will
make
copies
of
the
survey
instrument
and
this
ICR
available
as
a
reference
for
other
EPA
Program
Offices
undertaking
large­
scale
survey
and
program
evaluation
efforts.
A­
10
EPA
considered
the
possibility
of
using
an
electronic
bulletin
board
as
a
means
of
completing
the
survey.
The
Agency
concluded,
however,
that
the
cost
of
developing
a
computerized
survey
instrument
would
likely
outweigh
the
limited
benefit
of
potentially
reducing
a
relatively
minimal
burden
to
respondents
(
see
Section
6(
a)).
In
addition,
EPA
was
concerned
that
all
respondents
might
not
have
access
to
a
computer.

5(
c)
Small
Entity
Flexibility
EPA
does
not
believe
that
this
ICR
will
have
a
"
significant
economic
impact
on
a
substantial
number
of
small
entities."
The
IAQ
Practices
in
Schools
Survey
is
strictly
voluntary
and
targeted
to
individual
schools.
Most
of
the
respondents
are
expected
to
be
public
schools,
which
fall
outside
of
the
definition
of
a
"
small
entity"
provided
in
Section
601
of
the
Regulatory
Flexibility
Act.

5(
d)
Collection
Schedule
Information
collection
will
begin
upon
approval
of
this
ICR
and
the
assignment
of
an
OMB
control
number
to
the
survey
instrument.
The
collection
schedule
for
both
survey
distribution
cycles
is
expected
to
follow
the
approximate
time
line
presented
below.
This
schedule
will
be
adjusted
as
necessary
to
reflect
the
number
of
surveys
distributed
in
the
future.

Activity
Time
Line
Mail
surveys
to
respondents
Within
15
days
of
OMB
approval
of
ICR
Begin
telephone
surveys
with
respondents
32
days
after
mailing
of
surveys
(
allowing
who
did
not
respond
by
mail
two
days
for
delivery
of
the
survey)
Complete
telephone
surveys
30
days
after
telephone
surveys
begin
Complete
data
entry
of
survey
results
30
days
after
completion
of
telephone
surveys
Analyze
survey
findings
15
days
after
completion
of
data
entry
Report
survey
findings
30
days
after
completion
of
survey­
finding
analysis
4EPA
recognizes
that
a
small
additional
burden
will
be
placed
on
those
survey
recipients
who
complete
the
survey
by
mail
but
who
must
be
contacted
in
order
to
clarify
or
complete
the
information
provided
in
their
survey.
EPA
estimates
that
of
the
402
recipients
responding
by­
mail
(
per
survey
distribution
cycle),
approximately
25
percent,
or
100
respondents,
will
require
a
follow­
up
telephone
call.
Of
these,
it
is
estimated
that
two­
thirds,
or
approximately
67
respondents,
will
successfully
be
contacted.
The
Agency
expects
these
follow­
up
telephone
calls
to
last
no
more
than
five
minutes.
Therefore,
given
the
small
number
of
respondents
involved
and
the
limited
time
required,
EPA
did
not
include
this
burden
in
these
estimates.

A­
11
SECTION
VI
 
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
6(
a)
Estimating
Respondent
Burden
This
section
details
the
estimated
burden
to
respondents
participating
in
the
EPA
IAQ
Practices
in
Schools
Survey.
The
estimates
of
the
time
burden
involved
in
responding
to
the
survey
are
derived
from
the
pretest,
which
provided
information
on
the
staff
and
time
required
to
respond
to
the
survey.

Tables
6.1
and
6.2
present
a
summation
of
the
resulting
respondent
burden
estimates.

Table
6.1
 
Respondent
Burden/
Cost
for
Written
Surveys
Activities
Burden
Hours/
Respondent4
Review
Survey
Instructions
Compile
Survey
Information
Complete
Survey
Mail
Survey
to
EPA
0.3
0.4
0.4
0.2
Total
1.3
(
78
minutes)

Table
6.2
 
Respondent
Burden/
Cost
for
Telephone
Surveys
Activities
Burden
Hours/
Respondent
Review
Survey
Instructions
Compile
Survey
Information
Complete
Survey
0.3
0.4
0.1
Total
0.8
(
48
minutes)
A­
12
6(
b)
i
Estimating
Respondent
Costs
EPA
estimated
respondent
costs
using
the
burden
estimates
presented
above
in
Section
6(
a)
and
the
average
wage
figures
provided
by
the
Bureau
of
Labor
Statistics
for
each
of
the
respondents'

occupational
categories.
The
average
hourly
wage
rates
for
each
respondent
type
are
as
follows:

School
Principals
$
29.71
per
hour
Building
Engineers
$
18.40
per
hour
School
Nurses
$
19.56
per
hour
Teachers
$
16.15
to
18.22
per
hour
These
figures
were
taken
from
the
Department
of
Labor's
Bureau
of
Labor
Statistics
Occupational
Outlook
Handbook,
2000­
01
Edition,
at
http://
stats.
bls.
gov/
ocohome.
htm.
EPA
used
the
average
of
these
rate
ranges
to
determine
the
hourly
cost
(
labor
plus
overhead)
of
$
29.71
for
administrator
staff
(
i.
e.,
school
principals),
$
18.40
for
building
engineering
staff,
$
19.56
for
nursing
staff,
and
$
17.19
for
teaching
staff.

Based
on
data
from
the
Bureau
of
Labor
Statistics,
we
estimate
that
indirect/
fringe
costs
are
equal
to
approximately
25%
of
wage.
Therefore,
the
actual
hourly
cost
for
the
above
occupational
categories
are:

School
Principals
$
37.14
per
hour
Building
Engineers
$
23.00
per
hour
School
Nurses
$
24.45
per
hour
Teachers
$
20.19
to
22.73
per
hour
These
wage
rates
plus
indirect/
fringe
costs
will
be
used
to
estimate
costs
throughout
the
period
for
which
this
ICR
will
be
in
effect
.

Tables
6.3
to
6.10
present
the
individual
respondent
costs
associated
with
this
ICR.
The
respondent
costs
are
presented
by
respondent
type
and
survey
type.
Table
6.11
summarizes
the
individual
tables.
To
determine
the
respondent
burden
hours,
EPA
used
the
results
of
its
survey
pretest.
The
time
spent
on
each
activity
was
averaged
across
the
nine
respondents.
The
range
of
time
spent
on
each
activity
is
as
follows:

Review
Instructions
Five
to
60
minutes
Compile
Survey
Information
Zero
to
60
minutes
A­
13
Complete
Survey
(
Mail)
10
to
60
minutes
(
seven
surveys)
Complete
Survey
(
Phone)
Six
to
eight
minutes
(
two
surveys)
Mail
Survey
to
EPA
Five
to
40
minutes
(
seven
surveys)

The
average
burden
for
each
activity
is
presented
in
the
charts
that
follow.
A­
14
Table
6.3
 
Individual
Respondent
Cost
for
Mail
Surveys
 
School
Principals
Activities
Burden
Hours/
Respondent
School
Principals
@
$
37.14/
Hour
Review
Instructions
Compile
Survey
Information
Complete
Survey
Mail
Survey
to
EPA
0.3
0.4
0.4
0.2
$
11.14
$
14.86
$
14.86
$
7.43
Total
1.3
(
78
minutes)
$
48.29
Table
6.4
 
Individual
Respondent
Cost
for
Mail
Surveys
 
Building
Engineers
Activities
Burden
Hours/
Respondent
Building
Engineers
@
$
23.00/
Hour
Review
Instructions
Compile
Survey
Information
Complete
Survey
Mail
Survey
to
EPA
0.3
0.4
0.4
0.2
$
6.90
$
9.20
$
9.20
$
4.60
Total
1.3
(
78
minutes)
$
29.90
Table
6.5
 
Individual
Respondent
Cost
for
Mail
Surveys
 
School
Nurses
Activities
Burden
Hours/
Respondent
School
Nurses
@
$
24.45/
Hour
Review
Instructions
Compile
Survey
Information
Complete
Survey
Mail
Survey
to
EPA
0.3
0.4
0.4
0.2
$
7.34
$
9.78
$
9.78
$
4.89
Total
1.3
(
78
minutes)
$
31.79
Table
6.6
 
Individual
Respondent
Cost
for
Mail
Surveys
 
Teachers
Activities
Burden
Hours/
Respondent
Teachers
@
$
21.49/
Hour
Review
Instructions
Compile
Survey
Information
Complete
Survey
Mail
Survey
to
EPA
0.3
0.4
0.4
0.2
$
6.45
$
8.60
$
8.60
$
4.30
Total
1.3
(
78
minutes)
$
27.95
A­
15
Table
6.7
 
Individual
Respondent
Cost
for
Follow­
up
Phone
Surveys
 
School
Principals
Activities
Burden
Hours/
Respondent
School
Principals
@
$
37.14/
Hour
Review
Instructions
Compile
Survey
Information
Complete
Survey
0.3
0.4
0.1
$
11.14
$
14.86
$
3.71
Total
0.8
(
48
minutes)
$
29.71
Table
6.8
 
Individual
Respondent
Cost
for
Follow­
up
Phone
Surveys
­
Building
Engineers
Activities
Burden
Hours/
Respondent
Building
Engineers
@
$
23.00/
Hour
Review
Instructions
Compile
Survey
Information
Complete
Survey
0.3
0.4
0.1
$
6.90
$
9.20
$
2.30
Total
0.8
(
48
minutes)
$
18.40
Table
6.9
 
Individual
Respondent
Cost
for
Follow­
up
Phone
Surveys
 
School
Nurses
Activities
Burden
Hours/
Respondent
School
Nurses
@
$
24.45/
Hour
Review
Instructions
Compile
Survey
Information
Complete
Survey
0.3
0.4
0.1
$
7.34
$
9.78
$
2.45
Total
0.8
(
48
minutes)
$
19.57
Table
6.10
 
Individual
Respondent
Cost
for
Follow­
up
Phone
Surveys
 
Teachers
Activities
Burden
Hours/
Respondent
Teachers
@
$
21.49/
Hour
Review
Instructions
Compile
Survey
Information
Complete
Survey
0.3
0.4
0.1
$
6.45
$
8.60
$
2.15
Total
0.8
(
48
minutes)
$
17.20
A­
16
Table
6.11
 
Summary
of
Individual
Respondent
Costs
by
Respondent
and
Survey
Type
Respondent
and
Survey
Type
Individual
Respondent
Cost
Mail
Survey
 
School
Principals
$
48.29
Mail
Survey
 
Building
Engineers
$
29.90
Mail
Survey
 
School
Nurses
$
31.79
Mail
Survey
 
Teachers
$
27.95
Average
Respondent
Cost
for
Mail
Survey*
$
34.48
Follow­
up
Phone
Survey
 
School
Principals
$
29.71
Follow­
up
Phone
Survey
 
Building
Engineers
$
18.40
Follow­
up
Phone
Survey
 
School
Nurses
$
19.57
Follow­
up
Phone
Survey
 
Teachers
$
17.20
Average
Respondent
Cost
for
Follow­
Up
Phone
Survey*
$
21.22
*
EPA
has
chosen
to
average
respondent
costs
since
the
Agency
has
no
way
of
estimating
the
distribution
of
respondents
across
occupation
categories.

6(
b)
ii
Estimating
Capital,
and
Operations
and
Maintenance
Costs
EPA
does
not
expect
respondents
to
the
IAQ
Practices
in
Schools
Survey
to
incur
any
capital
or
operations
and
maintenance
(
O&
M)
costs.
This
information
collection
is
voluntary
and
does
not
require
special
equipment.
The
only
potential
O&
M
costs
to
be
incurred
would
be
those
associated
with
copying
the
completed
survey
for
the
school's
records
(
if
desired).
EPA
intends
to
enclose
an
EPA­
flocked
envelope,
including
postage,
in
which
respondents
may
return
the
survey
to
EPA.
The
Agency
estimates
respondent
costs
to
be
less
than
$.
50
per
survey.

6(
b)
iii
Capital/
Start­
up
vs.
Operating
and
Maintenance
Costs
Not
applicable
6(
b)
iv
Annualizing
Capital
Costs
Not
applicable
A­
17
6(
c)
Estimating
Agency
Burden
and
Costs
Table
6.12
provides
the
estimates
of
EPA's
burden
and
costs
associated
with
the
IAQ
Practices
in
Schools
Survey.
Wage
estimates
for
Agency
personnel
are
divided
into
three
general
categories
of
labor:
Management
(
GS­
15);
Technical
(
GS­
13);
and
Clerical
(
GS­
7).
EPA
personnel
participating
in
this
survey
effort
are
assumed
to
be
management
and
technical
personnel.
Civil
Service
wage
estimates
are
based
on
the
FY
2000
pay
scale
for
Washington,
DC
employees,
and
include
a
benefits
multiplier
of
1.6.
These
wage
rates
are
used
to
estimate
costs
throughout
the
period
for
which
this
ICR
is
in
effect.
EPA
contractor
personnel
will
also
support
this
survey
effort,
and
their
costs
are
calculated
as
an
Agency
burden.
Wage
rates
used
in
this
ICR
include:

Civil
Service
(
Manager)
$
73.55/
Hour
Civil
Service
(
Technical)
$
52.90/
Hour
Contractor
Personnel
$
63.00/
Hour
EPA
and
contractor
personnel
will
conduct
the
following
activities:

Table
6.12
Agency
Burden/
Cost
for
IAQ
Practices
in
Schools
Survey
(
Includes
First
and
Second
Survey
Distribution
Cycles)

Activities
Burden
Hours
Manager
@
$
73.55/
Hour
Technical
@
$
52.90/
Hour
Contractor
@
$
63.00/
Hour
Total
Hours
Develop
Survey
Form
Pretest
Survey
Form
Develop
Survey
Database
Distribute
Surveys
Conduct
Telephone
Surveys
Data­
enter
Results
Analyze
Results
Report
Findings
Quality
Assurance
0
hours
0
hours
0
hours
0
hours
0
hours
0
hours
0
hours
24
hours
0
hours
5
hours
1
hours
10
hours
0
hours
0
hours
0
hours
180
hours
120
hours
0
hours
15
hours
15
hours
222
hours
24
hours
388
hours
690
hours
360
hours
480
hours
90
hours
20
hours
16
hours
232
hours
24
hours
388
hours
690
hours
540
hours
624
hours
90
hours
Total
Hours
24
hours
316
hours
2,284
hours
2,624
hours
Total
Costs
$
1,765
$
16,716
$
143,892
$
162,373
In
addition
to
the
labor
burden
associated
with
the
distribution
of
IAQ
Practices
in
Schools
Survey,
EPA
will
also
incur
$
23,285
in
other
direct
costs.
These
costs
include
supplies
(
envelopes
and
mailing
labels),
postage,
delivery
charges,
and
long
distance
charges.
5Of
the
2,010
schools
surveyed,
EPA
expects
that
40
percent,
or
804
schools,
will
respond
to
the
survey
by
mail.
EPA
will
attempt
to
contact
the
remaining
60
percent
of
schools
(
1,206
schools)
by
telephone
to
remind
them
of
the
survey
and
encourage
them
to
participate.
These
schools
will
be
given
the
opportunity
to
respond
to
the
survey
by
telephone.
EPA
expect
that
two­
thirds
of
the
remaining
schools,
or
808
schools,
will
elect
to
respond
to
the
survey
by
telephone.
Consequently,
EPA
expects
a
total
survey
response
rate
of
80
percent
(
1,612
÷
2,010).

6804
mail
responses
÷
1,612
survey
respondents
=
49.9
percent
of
respondents
7808
telephone
responses
÷
1,612
survey
respondents
=
50.1
percent
of
respondents
8See
Footnote
3
9See
Table
6.11
A­
18
6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
EPA
anticipates
distributing
a
survey
to
2,010
schools
in
two
separate
survey
cycles
of
1,005
schools
each.
Of
those
potential
respondents,
EPA
estimates
80
percent5,
or
1,612
respondents,

will
elect
to
participate
in
this
information­
collection
effort.
Approximately
49.9
percent6
of
respondents,
or
804,
are
expected
to
respond
by
mail.
The
remaining
50.1
percent7
of
respondents,
or
808,
will
respond
by
telephone.

The
bottom­
line
burden
hours
for
this
information
collection
effort
are
as
follows:

Table
6.13
­­
Individual
Respondent
Burden
Totals
(
by
mail)

Survey
Activities
Time
Required
Review
Instructions
Compile
Survey
Information
Complete
Survey
Mail
Survey
to
EPA
Total
0.3
hours
0.4
hours
0.4
hours
0.2
hours
1.3
hours
(
78
minutes)

Total
Annual
Burden
(
of
mail
respondents)
=
(
Total
Hours
x
No.
of
Respondents)
÷
3
(
1.3
hours
x
804
respondents8)
÷
3
=
348
Hours
Average
Individual
Respondent
Collection
Cost
(
for
mail­
in
responses)
=
$
27.60/
Respondent9
Total
Annual
Costs
for
All
Respondents
(
who
respond
by
mail):
(
Individual
Respondent
Collection
Cost
x
No.
of
Respondents)
÷
3
10See
Footnote
3
11See
Table
6.11
A­
19
($
27.60
x
804)
÷
3
=
$
7,397
Table
6.14
­­
Individual
Respondent
Burden
Totals
(
by
phone)

Survey
Activities
Time
Required
Review
Instructions
Compile
Survey
Information
Complete
Survey
Total
0.3
hours
0.4
hours
0.1
hours
0.8
hours
(
48
minutes)

Total
Annual
Burden
(
of
telephone
respondents)
=
(
Total
Hours
x
No.
of
Respondents)
÷
3
(
0.8
hours
x
80810)
÷
3
=
215
Hours
Average
Individual
Respondent
Collection
Cost
(
for
telephone
responses)
=

$
16.95/
Respondent11
Total
Annual
Costs
for
All
Respondents
(
who
respond
by
telephone):
(
Individual
Respondent
Collection
Cost
x
No.
of
Respondents)
÷
3
($
16.95
x
808)
÷
3
=
$
4,565
Total
Hourly
Burden:
(
Respondent
Hours
Per
Survey
(
Mail)
x
No.
of
Respondents)
+

(
Respondent
Hours
Per
Survey
(
Phone)
x
No.
of
Respondents)

(
1.3
x
804)
+
(.
8
x
808)
=
1,692
Hours
Total
Cost:
(
Individual
Respondent
Collection
Cost
(
Mail
Respondent)
x
No.
of
Respondents)
+

(
Individual
Respondent
Collection
Cost
(
Phone
Respondent)
x
No.
of
Respondents)

($
27.60
x
804)
+
($
16.95
x
808)
=
$
35,886
A­
20
Table
6.15
­­
Total
Respondent
Burden
and
Costs
Survey
Type
Number
of
Respondents
Total
Hours
Total
Burden
Costs
Mail
804
1,046
$
22,190
Phone
808
646
$
13,696
Total
1,612
1,692
$
35,886
The
breakout
for
EPA
activities
associated
for
this
survey
effort
can
be
found
in
Table
6.12.

Table
6.16
details
the
bottom­
line
burden
for
EPA
associated
with
this
survey
effort.

Table
6.16
­­
EPA
Bottom­
line
Labor
Burden
Number
of
Hours
Hourly
Rate
Total
Costs
24
$
73.55
(
Manager)
$
1,765
316
$
52.90
(
Technical)
$
16,716
2,284
$
63.00
(
Contractor)
$
143,892
Total
2,624
$
162,373
6(
e)
i
Bottom­
Line
Burden
Hours
and
Cost
Tables
Table
6.17
details
the
total
bottom­
line
burden
(
respondent
and
EPA)
associated
with
this
survey
effort.
Table
6.12
in
Section
6(
c)
Estimating
Agency
Burden
and
Costs
and
Tables
6.13
­
6.16
in
Section
6(
d),
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs,
detail
how
these
total
figures
were
derived.

Table
6.17
 
Bottom­
line
Burden
Hours
and
Cost
Burden
Category
Burden
Costs
Burden
Hours
Respondent
$
35,886
1,692
hours
EPA
Labor
$
162,373
2,624
hours
EPA
Other
Direct
Costs
$
23,285
N/
A
Total
Bottom­
line
Burden
$
221,544
4,316
hours
A­
21
6(
e)
ii
The
Agency
Tally
See
Section
6(
c),
Estimating
Agency
Burden
and
Costs,
for
information
on
how
the
bottom­
line
Agency
costs
were
derived.

6(
e)
iii
Variation
in
the
Annual
Bottom­
Line
Since
the
majority
of
respondents
will
only
participate
once
in
the
IAQ
Practices
in
Schools
Survey
during
the
clearance
period
requested,
EPA
does
not
expect
any
variation
in
the
annual
bottom­
line.

6(
f)
Reasons
for
Change
in
the
Burden
This
section
is
not
applicable
since
this
is
a
new
ICR.

6(
g)
Burden
Statement
Public
reporting
burden
for
this
collection
of
information
is
estimated
to
range
between
0.8
and
1.3
hours,
or
from
48
to
78
minutes
per
response.
This
includes
time
for
reviewing
survey
instructions,
compiling
survey
information,
completing
the
survey,
and
mailing
the
survey
to
EPA.

The
average
respondent's
response
cost
is
$
27.60
for
surveys
completed
by
mail
and
$
16.96
for
surveys
completed
by
telephone.

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
to
the
Director,

Collection
Strategies
Division,
Office
of
Environmental
Information,
(
OEI),
U.
S.
Environmental
Protection
Agency,
MC
2822,
1200
Pennsylvania
Avenue,
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
1885.01
in
any
correspondence.
