  SEQ CHAPTER \h \r 1 

The SunWise Program

ICR # 1904.03

  DATE \@ "MMMM d, yyyy"  September 14, 2007 

U. S.  Environmental Protection Agency

Office of Air and Radiation





Part A of the Supporting Statement

	Identification of the Information Collection

1(a)	Title of Information Request

The title of this Information Collection Request (ICR) is The SunWise
Program (ICR# 1904.03).

1(b)	Short Characterization/Abstract

The SunWise Program was initiated in 1998 through a statutory mandate
under Title IV of the Clean Air Act.  The long term objective of the
SunWise Program is to reduce the incidence of, and morbidity and
mortality from, skin cancer, cataracts, and other UV-related 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, and the largely preventable health risks from
overexposure to the sun, as well as simple sun safety practices.  All
educators interested in participating in this partnership program are
asked to register using an online form
(www.epa.gov/sunwise/becoming.html and
www.epa.gov/sunwise/becoming_partner.html) or a hard copy form
distributed by EPA.  EPA will use the information provided through this
registration to maintain a database of participating schools and
organizations and a mailing list for information distribution purposes.
Participating schools and organizations receive a variety of materials,
including a classroom “Tool Kit” of games, songs, puzzles, story
books, videos, access to the internet UV intensity mapping/graphing
tools, 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.  Randomly selected 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. The surveys will be mailed out to Program participants once
they have registered.  Survey responses are voluntary and anonymous. 

Additionally, SunWise is developing an on-line interactive SunWise Sun
Safety Certification Program. When it is up and running, the
certification program will allow for students, adults, organizations,
and employers to develop credentials on sun safety awareness and
behaviors. In order to gauge the certification program’s
effectiveness, we will be collecting a small amount of information
including the user’s first initial and last name, type of user, length
of time to complete the tutorial, percentage of individuals who start
the tutorial that complete it, percentage of tutorial completed by each
user, and the accuracy of individuals completing the tutorial. Users
types include: informal educators (at camps; parks; recreation programs;
museums; science and health education centers; sports organizations;
lifeguards; childcare and after school programs; high schools, colleges
and university staff and students working with youth; health and medical
organizations, etc.), children in grades K-8, and teachers and other
school staff. This project is still in development.

TERMS OF CLEARANCE:

On November 2, 2001, OMB approved ICR #1904.01 with Terms of Clearance. 
EPA has addressed OMB’s terms in the following manner.

This collection is approved in part and disapproved in part. EPA is
approved to collect registration information and to conduct the
requested student survey and teacher survey. These portions of the
collection are approved for two years, until November 2003. OMB
understands that EPA no longer intends to collect information under the
Parent Survey and the School Administrator Survey. These two surveys are
not approved. OMB has adjusted the burden of the collection accordingly
from EPA's request. 

EPA Response: We will not be surveying parents or school administrators
under this ICR renewal.

As discussed in Part B of the revised supporting statement, EPA plans to
 assess two sampling issues in Fall 2002 based on results from the first
year of the student survey: (1) whether it is necessary to include in
the sampling protocol an  approach to stratify between warm and cool
states, and (2) whether it is necessary to include an additional
sampling stage to sample classrooms within a school that has been 
selected for participation. EPA should report to OMB its findings with
regard to these issues before beginning the second year of sampling, and
advise OMB whether it intends in the second year of the collection to
(1) stratify  between warm and cool states in the first stage of
sampling, 

EPA Response (sent to OMB on 8/29/02): We have conducted this analysis
and found no differences between the students in the 37 cooler states
versus the 13 warm states, as categorized by the UV Index values. We
measured change in scores from pretest to posttests on children's
knowledge of sun protection, attitudes toward the sun, and current sun
protection practices and found minimal differences in the change.
Therefore, with no differences between the two groups, there would be no
reason to stratify our findings. 

and/or (2) add a sampling stage to sample classrooms within a selected
school. 

EPA Response (sent to OMB on 8/29/02): We analyzed the composition of
registrants in the SunWise database by region of the country and the
number of schools that contained more than one classroom. It appears
that 75 percent of schools in warm and cool climates have no more than 1
classroom per school with negligible difference by region. There is
little evidence of clustering or differences in clustering between
regions of the country. If that were the case, we would have to account
for this effect by performing tests of intraclass correlation.

OMB also notes that EPA must include the OMB number, expiration date,
and Paperwork Reduction Act notice on the teacher survey before using
that instrument to collect information.

EPA Response: All information is now included on the teacher survey. 
See attachment #3 for verification.

	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.  Educators
will be asked to fill out a simple registration form, which we use to
mail out the program materials and keep track of the Program’s:

geographic reach (Which states/regions have SunWise schools?);

grade-level and subject-matter distribution (How many 1st grade teachers
are using SunWise? How many math teachers are using SunWise? etc.); and

student participation level (How many students is SunWise potentially
reaching?).

Surveys to be administered include:

Student survey to identify current sun safety knowledge and behaviors
among students; and

Teacher questionnaire for measuring their receptivity to the educational
component of 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 Sun Safety Certification Program is voluntary and will
remain anonymous and confidential. No contact or demographic information
other than the user’s last name and type will be stored. By collecting
the user’s first initial and last name, it will allow the user to go
back and complete the tutorial at a later date. This will help EPA
determine which audiences are using the resource and if it is too
difficult or too long, by answering these questions:

		Who is using the certification program?

		How long does the tutorial take?

		Are users completing the tutorial?

		How much of the tutorial are they completing? and

		How well are users learning from the tutorial?

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 its 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 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. 

To EPA/SunWise’s knowledge, there is no other sun safety certification
available in the US, therefore it is essential that accurate information
on the users and use of the certification program be collected for
program refinement.

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

Official notice of this proposed collection appeared in the Federal
Register on Monday, February 12, 2007 (72 FR 6564).  One comment was
received.  The individual requested that the information not be
collected, but gave no justification for their claim.  The comment was
considered in this final ICR renewal.

3(c)	Consultations

The following professionals were consulted during the development of the
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.

SunWise depends on certification program information to:

	

determine which tutorial to provide to the user;

measure how many and what type of users are becoming certified;

ensure the tutorial does not take too long to complete;

ensure rigor and enthusiasm for the tutorial; and 

determine whether or not the tutorial is delivering the information in
an easy-to-understand manner.

Conducting the surveys and information collection 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 Program.

3(f)	Confidentiality

		

Names of participating schools and organizations may be made public. 
All names of registered educators 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. For the certification program, users’ first initial and last name
will be confidential. EPA will make public how many informal educators,
teachers and students have taken and completed the tutorial.

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 and NAICS Codes

Entities potentially affected by this action are elementary and middle
school students, and educators (SIC Div. I: Group 8211; NAICS code:
61111).

	

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.  (Please note that during discussions with OMB for the initial
ICR approval, it was determined that an abbreviated burden statement
would be appropriate for this survey group.)

Teacher Evaluation of Classroom Activities (Attachment 3):  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. This information can also be submitted online.

SunWise Sun Safety Certification Tutorial (Under development; questions
in Attachment 4):  Certification program users will be asked to provide
their first initial and last name so they can stop and return to
complete the tutorial at their leisure, and their user type. The
information will be used to pull up the correct tutorial and to print
the certificate upon completion. The time to enter this information will
be minimal at 1 minute.

Registration forms can be submitted electronically or in hard copy using
postage-paid envelopes provided by EPA. Likewise, teachers are given
postage-paid envelopes in which to return their completed surveys, along
with the surveys returned to them by the students.  The teacher survey
is also available electronically.  Neither the registration nor the
surveys require that respondents keep records, make photocopies, or
maintain files.

										

5.  The Information Collected

5(a)	Agency Activities

The Agency activities associated with registration of participants done
through the

SunWise Program consists of the following:

	Maintain participant database; and

	Maintain mailing list for information distribution purposes.

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

Develop collection instruments;

Answer respondent questions;

Audit and/or review data submissions;

Reformat and distribute the data; and

Store the data.

The Agency activities associated with the certification program done
through the SunWise Program consists of the following:

Develop certification program/tutorial;

Store and consolidate data;

Review consolidated data; and

Refine tutorial accordingly.

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, mailed and
electronic surveys, and electronic records of tutorial inputs. 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.

EPA will not engage in statistical surveying.  Respondents will be
randomly selected from schools within all 50 states.

EPA plans to review data collected from the certification
program/tutorial and make refinements to the program as necessary.

													

5(c)	Small Entity Flexibility

Not applicable.

5(d)	Collection Schedule

All educators are required to register for the Program if they wish to
receive the Tool Kit (www.epa.gov/sunwise/becoming.html and
www.epa.gov/sunwise/becoming_partner.html) and regular program updates. 
Student surveying is done using random sampling.  The SunWise partner
schools 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 surveys are administered once
during the school year, and are done on a voluntary basis, thus all
educators registered in SunWise have the opportunity to complete a
survey.  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.  All educators and students are required to provide their first
initial, last name and user type in order to take part in the on-line
certification tutorial.  There is no collection schedule for
registration or certificate program enrollment, as it is ongoing.  

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 registrant burden
of 10 minutes.

Annual estimated respondent burden: 

Annual Respondent Burden- Registration

Registrant Group	Hour Burden

Educator	.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 20 minutes to complete. 

Annual estimated respondent burden: 

Annual Respondent Burden- Surveys

Survey Group	Hour Burden

Student	.33

Educator	.33



	Users will only be asked to enter their first initial and last name and
to choose a user type once during their participation in the tutorial
for a total registrant burden of 1 minute.

Annual estimated respondent burden: 

Annual Respondent Burden –Tutorial/Certificate

Survey Group	Hour Burden

Student	.04

Educator	.04



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.  In order to account for benefits and
overhead, the average hourly wage rate of $36.67 for a teacher was
increased by 110% for a labor cost of $77.01 per hour for teachers.

	Annual Respondent Burden and Cost- Registration

Registrant Group	# of responses per participant	Hour Burden	Labor Cost

Educator	1	.17	.17 * $77.01 = $13.09



Annual Respondent Burden and Cost - Surveys

Survey Group	# of responses per participant	Hour Burden	Labor Cost

Student	2	.33	2(.33 * 0) = 0

Educator	1	.33	.33 * $77.01 = $25.41



Annual Respondent Burden and Cost – Tutorial/Certificate

Survey Group	# of responses per participant	Hour Burden	Labor Cost

Student	1	.04	2(.04 * 0) = 0

Educator	1	.04	.04 * $77.01 = $3.08



	The respondents will have no capital/startup or O&M costs.

6(c)	Estimating Agency Burden and Cost

	Registration information collection is done primarily through a website
database feature.  The start-up cost associated with designing the
registration web page was approximately $25,000.  Operating and
Maintenance (O&M) Costs associated with maintenance of the website are
estimated to be 4 hours/month or 48 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 ($36.26/hour using the salary associated
with this grade and step, multiplied by a benefits factor of 1.6),
making the total annual cost $2,784.76.  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 50 hours per year
at a GS 5 Step 1 pay level ($14.56/hour using the salary associated with
this grade and step, multiplied by a benefits factor of 1.6). Total
hours (50) multiplied by $25.73 per hour amounts to a total agency labor
cost of $1164.80 per annum. 

Agency Burden and Costs - Registration

	Burden Hours	Total Costs ($)

EPA (Annual)	98	$3,949.56

EPA (3-Year ICR)	294	$11,848.68



	The contractor assists EPA in data collection and analysis.  The
contractor also provided technical support in the development of the
surveys.  To perform these functions, EPA has contracted for a total of
850 professional hours.  At an average rate of $82.35 per hour, the
total cost for the contractor is $70,000 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 ($58.02/hour using the salary associated with this grade and step,
multiplied by a benefits factor of 1.6).  Total hours (48) multiplied by
$58.02 per hour amounts to a total agency labor cost of $2,784.96/per
annum.

	Agency Burden and Costs- Surveying

	Burden Hours	Total Costs ($)

EPA (Annual)	48	$2,784.96

EPA (3-Year ICR)	144	$8,354.88



	The contractor will create and maintain the tutorial, including the
data collection component.  To perform this function, EPA has contracted
for a total of 410 professional hours.  At an average rate of $130.00
per hour, the total cost for the contractor is $53,300 for startup
costs, and 100 hours per year at a cost of $13,000, for maintenance each
year after.  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 ($58.02/hour using the
salary associated with this grade and step, multiplied by a benefits
factor of 1.6).  Total hours (48) multiplied by $58.02 per hour amounts
to a total agency labor cost of $2,784.96/per annum.

	Agency Burden and Costs – Tutorial/Certification

	Burden Hours	Total Costs ($)

EPA (Annual)	48	$2,784.96

EPA (3-Year ICR)	144	$8,354.88



												

6(d)	Estimating the Respondent Universe and Total Burden Costs

(A)

Number to register	(B)

Total Hours	(C)

Rate per hour ($)	(D)

# of responses	(E)

Total Cost

E=B*C

3,500 Educators	595	$77.01	3,500	$45,820.95



Total (Annual)                     	595

3,500	$45,820.95

ICR Total (3 years)             	1,785

10,500	 $137,462.85



(A)

Number to be surveyed	(B)

Total Hours	(C)

Rate per hour ($)	(D)

# of responses	(E)

Total Cost

E=B*C

1,500 Students	1,000	0	3,000	0

1,000  Educators	333	$77.01	1,000	 $26,510.13

Total (Annual)                     	1,333

4,000	 $26,510.13

ICR Total (3 years)             	3,999

12,000	 $79,530.39



(A)

Number to Take Tutorial	(B)

Total Hours	(C)

Rate per hour ($)	(D)

# of responses	(E)

Total Cost

E=B*C

100 Students	3.33	0	100	0

1000 Educators	33.33	$77.01	1,000	 $2,566.74

Total (Annual)                     	36.66

1,100	 $2,566.74

ICR Total (3 years)             	109.98

3,300	 $7,700.22



ICR Total-Registration + Surveys + Tutorial (annual)             
1,964.66

8,600	 $74,897.82

ICR Total-Registration + Surveys + Tutorial (3 years)             
5,893.98

25,800	 $224,693.46



6(e)Bottom Line Burden Hours and Cost Tables

Bottom Line Burden and Costs (3-Year ICR)

	Burden Hours	Total Costs ($)

Students	3,010	0

Educators	2,884	$224,693.46

EPA	584	$28,276.50

O&M Costs (EPA Contractor)	3,160	$327,300.00

Total	9,638	$580,269.96



6(f)	Reasons for Change in Burden						

	We added hours for the new tutorial/certification program. 
Additionally, the number of educators registering per year has increased
to 3,500 to correspond with PART goals.  Combining that with inflation
and changing contractors, the total burden has increased. 

6(g)	Burden Statement 

	The annual public reporting and record keeping burden for this
collection of information is estimated to average 10 minutes per
response for the registration, 20 minutes per response for the two
surveys, and 2 minutes per response for the tutorial/certification
program.  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 requirements; 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.		

	To comment on 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,
EPA has established a public docket for this ICR under Docket ID No.
EPA-HQ-OAR-2007-0069, which is available for public viewing at the Air
and Radiation Docket and Information Center in the EPA Docket Center
(EPA/DC), EPA West, Room 3334, 1301 Constitution Ave., NW, Washington,
DC. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to
4:30 p.m., Monday through Friday, excluding legal holidays.  The
telephone number for the Reading Room is (202) 566-1744, and the
telephone number for the Air and Radiation Docket and Information Center
is (202) 566-1742.  An electronic version of the public docket is
available at www.regulations.gov.  This site can be used to submit or
view public comments, access the index listing of the contents of the
public docket, and to access those documents in the public docket that
are available electronically.  When in the system, select “search,”
then key in the Docket ID Number identified above.  Also, you can send
comments to the Office of Information and Regulatory Affairs, Office of
Management and Budget, 725 17th Street, NW, Washington, DC
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