Page
1
Information
Collection
Request
1941.02
Evaluation
of
the
PrintSTEP
State
Pilot
Program
PART
A
OF
THE
SUPPORTING
STATEMENT
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1(
a)
Title:
Evaluation
of
the
PrintSTEP
State
Pilot
Program
1(
b)
Short
Characterization/
Abstract
PrintSTEP,
which
stands
for
"
Printers'
Simplified
Total
Environmental
Partnership,"
was
initiated
as
part
of
the
EPA's
"
Common
Sense
Initiative,"
the
goal
of
which
was
to
create
environmental
protection
strategies
that
are
cleaner
for
the
environment
and
cheaper
and
smarter
for
industry
and
taxpayers.
Representatives
from
federal,
state,
and
local
governments,
industry,
environmental
justice
groups,
and
labor
organizations
developed
PrintSTEP
by
redesigning
the
permitting
process
currently
in
effect
for
this
industry.
PrintSTEP
is
a
single
enforceable
agreement
that
regulates
a
printing
facility's
air,
water,
and
hazardous
waste
streams
all
at
once.
It
combines
environmental
requirements
for
printing
facilities
into
one
system,
and
addresses
both
federal
and
state
requirements.
It
is
a
voluntary
pilot
program
and
it
does
not
change
the
existing
environmental
emissions
or
release
standards
for
the
printing
industry.
Instead,
it
changes
the
process
of
implementing
those
standards
to
improve
efficiency
and
environmental
performance.
This
alternative
regulatory
scheme
incorporates
meaningful
public
involvement
in
the
regulatory
process,
provides
printers
with
one
regulatory
agreement
for
all
media,
provides
flexibility
for
printers
to
make
many
types
of
process
changes
without
additional
paperwork,
and
promotes
pollution
prevention
practices.
Details
of
the
PrintSTEP
program
are
included
in
three
project
documents:
a
State
Guide
for
the
pilot
states,
a
Plain
Language
Workbook
Template
for
participating
printers,
and
a
Community
Handbook
for
interested
community
members.
These
three
documents
are
publicly
available
at
http://
www.
epa.
gov/
sectors/
prntstep.
htm.

EPA
has
funded
three
states
(
Missouri,
Minnesota
and
New
Hampshire)
through
cooperative
agreements
to
test
the
PrintSTEP
concepts
in
a
pilot
project.
Currently,
the
three
pilot
states
are
preparing
to
start
to
solicit
the
participation
of
volunteer
printing
facilities.
These
printers
will
prepare
a
single
PrintSTEP
application
(
covering
their
waste
water,
storm
water,
hazardous
waste
and
air
emissions)
and
submit
it
to
the
state
agency.
In
many
cases,
this
single
application
will
be
a
substitute
for
several
sets
of
paperwork
a
printer
may
currently
be
required
to
complete
for
each
individual
waste
stream.
Another
key
component
of
PrintSTEP
is
meaningful
public
involvement.
All
PrintSTEP
applications
will
be
available
for
public
review,
and
for
many
applications,
community
members
will
have
an
opportunity
to
provide
comments
or
participate
in
public
meetings
and
discussions
with
the
printers.

As
a
pilot
project,
EPA
must
conduct
a
thorough
evaluation
to
help
determine
whether
or
not
to
go
forward
with
further
implementation
of
the
program.
In
the
process
of
doing
so,
improvement
measures
for
the
program
can
be
implemented.
The
evaluation
of
the
PrintSTEP
pilot
program
aims
to
systematically
identify
the
impacts
the
program
has
had
on
three
types
of
stakeholders:
Page
2
printers,
community
residents,
and
the
state
government
agencies
administering
the
program.
A
primary
goal
of
the
evaluation
is
to
answer
the
question:
What
difference
has
PrintSTEP
made
to
each
of
these
three
types
of
stakeholders?

The
evaluation
will
include
a
telephone
survey
of
participating
printers
and
a
comparison
group
of
non­
participating
printers.
A
baseline
survey
of
these
two
groups
will
be
conducted
at
the
start
of
the
pilot
project,
an
interim
survey
will
be
conducted
mid­
way
through
the
pilot,
and
a
post­
pilot
survey
will
be
conducted
at
the
conclusion
of
the
pilot
project.
These
surveys
will
be
administered
by
an
EPA
contractor.
Additional
information
on
printers'
environmental
releases
and
wastes
will
come
from
the
PrintSTEP
applications
collected
by
the
pilot
states.
Nonparticipating
printers
in
the
comparison
group
will
be
asked
to
supply
the
same
type
of
information
as
is
on
the
PrintSTEP
application.
The
community's
experience
with
the
PrintSTEP
pilot
will
also
be
evaluated
through
a
telephone
survey
conducted
approximately
mid­
way
through
the
pilot
project.
The
pilot
states
will
conducts
this
survey.
The
experiences
of
the
pilot
states
in
the
PrintSTEP
program
will
be
evaluated
through
in­
depth
interviews
with
the
PrintSTEP
coordinators
in
each
state.
This
information
collection
effort
is
not
included
in
this
ICR
as
fewer
than
ten
interviews
will
be
conducted.

The
results
of
the
evaluation
will
be
used
by
EPA
and
states
considering
the
expansion
of
the
PrintSTEP
program
beyond
the
pilot
stage.
Additionally,
the
multi­
stakeholder
representatives
(
and
their
constituents)
who
contributed
their
time
and
expertise
over
the
four­
year
development
of
PrintSTEP
will
also
use
the
evaluation
results
to
assess
their
interest
in
participating
in
a
program
to
expand
the
implementation
of
PrintSTEP
concepts.

2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
2(
a)
Need/
Authority
for
the
Collection
To
evaluate
the
effectiveness
of
the
pilot
project,
information
needs
to
be
collected
from
the
pilot
project
participants.
Without
a
comprehensive
evaluation,
the
ability
of
the
pilot
project
to
inform
future
policy
(
the
purpose
of
conducting
and
sponsoring
the
pilot
in
the
first
place)
would
be
lost.

Delegation
1­
47
gives
the
Office
of
Enforcement
and
Compliance
Assurance
the
authority
"
To
approve
grants
and
cooperative
agreements
aimed
at
fostering
environmental
enforcement
and
improving
compliance
with
environmental
law
in
the
U.
S.
and
foreign
countries
to
public
and
private
agencies,
organizations,
and
institutions;
colleges,
universities,
and
other
institutions
of
higher
education;
federally
recognized
tribal
entities;
private
individuals,
and
to
any
others
for
activities
including,
but
not
limited
to,
training,
studies,
investigations,
surveys,
public
education
programs,
and
research,
and
to
approve
fellowships;
where
authorized
under:
Clean
Air
Act,
Section
103;
Clean
Water
Act,
Section
104;
Solid
Waste
Disposal
Act,
Section
8001;
Federal
Insecticide,
Fungicide,
and
Rodenticide
Act,
Section
20;
Toxic
Substances
Control
Act,
Section
10;
Marine
Protection,
Research,
and
Sanctuaries
Act,
Section
203;
Safe
Drinking
Water
Act,
Section
1442;
Comprehensive
Environmental
Response,
Compensation
and
Liability
Act,
Section
311;
and
Indian
Environmental
General
Assistance
Program
Act,
Section
11."
Page
3
2(
b)
Practical
Utility/
Users
of
the
Data
The
evaluation
results
will
be
used
by
EPA
and
states
to
determine
whether
the
PrintSTEP
concepts
should
be
adopted
for
national
application.
The
results
will
measure
the
success
of
the
PrintSTEP
concept
and
tools,
and
will
be
published
in
a
final
EPA
report
addressing
what
changes
have
taken
place
in
PrintSTEP
facilities,
and
whether
or
not
those
changes
can
be
attributed
to
PrintSTEP.
Quantitative
and
qualitative
results
will
be
tabulated
for
the
baseline,
midpoint
and
end
of
the
program,
and
the
following
research
questions
will
be
addressed:
°
Does
PrintSTEP
effect
emissions,
wastes
and
discharges
from
printing
(
both
overall
and
for
each
medium)?
°
Has
PrintSTEP
changed
printers'
use
of
specific
pollution
prevention
practices?
°
Can
states
administer
PrintSTEP
as
a
multi­
media
program?
°
Does
PrintSTEP
improve
efficiency
for
the
state
regulators?
°
Do
printers
have
a
better
understanding
of
their
regulatory
requirements
under
PrintSTEP?
°
Does
PrintSTEP
effect
printers'
ability
to
respond
to
market
conditions?
°
Does
PrintSTEP
provide
an
opportunity
for
meaningful
public
involvement?
°
Is
PrintSTEP
cost­
effective
for
all
stakeholders?

Conducting
and
evaluating
the
PrintSTEP
pilot
contributes
to
most
Agency
goals,
as
stated
in
EPA's
Strategic
Plan
(
EPA
190
R­
00­
002).
The
Strategic
Plan
stresses
EPA's
promotion
of
innovative
approaches
such
as
PrintSTEP
which
"
streamlined
regulatory
processes,
cut
paperwork,
built
more
flexibility
into
regulations,
established
new
voluntary
programs
and
partnerships,
and
adopted
new
cross­
Agency,
cross­
media
perspectives
on
health
and
environmental
problems."
In
particular,
the
data
collection
for
the
PrintSTEP
pilot
evaluation
contributes
to
EPA
Goal
1
(
Clean
Air),
Goal
2
(
Clean
and
Safe
Water),
Goal
4
(
Preventing
Pollution),
Goal
5
(
Better
Waste
Management),
and
Goal
7
(
Quality
Environmental
Information).

3.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
3(
a)
Nonduplication
The
data
requirements
for
the
study
have
been
carefully
reviewed
to
ensure
that
the
needed
information
cannot
be
obtained
from
other
sources.
The
information
requested
either
in
the
telephone
interviews
or
the
written
portion
of
the
evaluation
is
not
available
through
any
other
source
within
the
EPA,
nor
is
it
available
through
sources
outside
the
Agency.
This
pilot
project
has
not
been
previously
conducted,
and
therefore,
has
not
been
evaluated.

3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
In
compliance
with
the
1995
Paperwork
Reduction
Act,
EPA
solicited
public
comments
during
a
60­
day
period
prior
to
submission
of
the
ICR
to
OMB.
EPA
issued
a
Federal
Register
notice
announcing
the
ICR
and
providing
a
burden
estimate
on
March
14,
2000,
FR
Vol.
65,
No.
14
(
see
Appendix
E).
No
comments
were
received
before
the
comment
period
ended
on
May
15,
2000.
1
It
is
not
possible
to
collect
baseline
data
from
community
participants,
because
they
will
be
unknown.
It
was
determined
that
the
best
way
to
get
accurate
and
timely
information
from
this
group
would
be
to
survey
them
soon
after
they
have
completed
going
through
the
PrintSTEP
process.

Page
4
3(
c)
Consultations
The
research
design,
data
collection
instruments
and
data
collection
plan
were
developed
by
Abt
Associates
Inc.,
under
U.
S.
EPA
contract
68­
W6­
0021.
The
work
was
done
with
close
consultation
and
significant
input
from
U.
S.
EPA
and
the
PrintSTEP
stakeholder
representative
group.
This
group
included
representatives
of
the
parties
from
whom
the
information
is
to
be
obtained,
namely
printers
and
community
members.
This
group
was
directly
involved
with
designing
the
evaluation
strategy
and
data
collection
instruments,
ensuring
that:
the
environmental
benefit
of
the
pilot
project
is
thoroughly
tracked;
the
data
collection
instruments
are
technically
sound;
the
instructions
are
clear;
the
terminology
is
coherent,
unambiguous,
and
understandable
to
respondents;
respondent
burden
is
minimized;
and
the
data
is
obtainable,
but
has
not
been
collected
previously.
Additionally,
the
contractor's
survey
research
professionals
reviewed
the
survey
instruments
to
check
that
items
are
unambiguous,
unbiased,
nonrepetitive,
and
properly
sequenced,
skip
patterns
are
clear,
and
answer
categories
are
mutually
exclusive
and
collectively
exhaustive.

3(
d)
Effects
of
Less
Frequent
Collection
Survey
data
will
be
collected
from
printers
in
each
of
the
PrintSTEP
pilot
states
at
three
separate
points
in
time:
baseline,
interim,
and
at
the
end
of
the
pilot.
Data
will
be
collected
from
community
members
at
a
single
point
in
time
during
the
pilot.
1
The
pilot
is
expected
to
last
for
approximately
three
years
and
the
printers'
data
collections
are
expected
to
occur
approximately
in
the
summers
of
2001,
2002,
and
2003.
The
community
data
collection
is
expected
to
occur
in
2002.
Surveying
printers
at
these
three
points
in
time
is
necessary
to
reliably
measure
the
changes
brought
about
by
the
PrintSTEP
program.
Less
frequent
data
collection
could
jeopardize
the
quality
of
the
results.
For
example,
a
printer
may
not
accurately
recount
the
actions
taken
related
to
the
public
meeting
if
he/
she
is
asked
about
that
meeting
a
year
or
more
after
it
occurred.

3(
e)
General
Guidelines
This
information
collection
adheres
to
the
general
guidelines
set
forth
by
the
Office
of
Management
and
Budget
(
OMB).

3(
f)
Confidentiality
All
survey
respondents
will
be
assured
that
the
information
they
provide
will
be
used
only
for
the
purpose
of
this
research.
No
data
will
be
released
in
a
form
that
can
identify
individual
respondents.

Prior
to
beginning
the
telephone
surveys,
all
respondents
will
receive
an
advance
letter
from
their
local
trade
association
and/
or
the
state
environmental
agency.
The
letter
will
discuss
EPA's
sponsorship
of
the
survey,
explain
the
importance
and
intended
applications
of
the
survey
and
request
the
respondent's
cooperation.
The
advance
letter
will
indicate
that
the
respondent
will
Page
5
soon
receive
a
telephone
call
from
a
survey
research
firm,
and
will
also
stress
that
the
respondent's
contribution
to
the
survey
is
voluntary.

Prominent
in
the
advance
letter
will
be
an
assurance
from
EPA
and
the
contractor
collecting
the
data
that
information
will
be
presented
in
aggregate
form
only
without
individual
identifiers.
This
assurance
will
be
reiterated
proceeding
the
administration
of
the
telephone
interviews.

Several
steps
will
be
taken
to
ensure
confidentiality
of
individual
responses.
The
survey
will
be
conducted
by
the
survey
research
firm's
staff
who
will
employ
the
following
procedures:

°
All
employees
sign
a
blanket
confidentiality
agreement
at
the
time
of
hire;
°
Access
to
data
files
containing
unique
identifiers
is
limited
through
password
protection;
°
Internal
ID
encoding
will
be
used
instead
of
individual
identifiers;
and
°
No
data
on
individual
respondents
will
be
released
or
identifiable
in
any
published
reports
or
analyses;
information
will
be
presented
in
aggregations
only.
EPA
staff
will
not
receive
any
records
linking
respondents'
names
to
survey
identification
codes.

3(
g)
Sensitive
Questions
Sensitive
questions
are
defined
in
the
ICR
instructions
as
"
questions
concerning
sexual
behavior
or
attitudes,
religious
beliefs,
or
other
matters
usually
considered
private."
This
information
collection
does
not
include
sensitive
questions.

4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
4(
a)
Respondent/
Standard
Industrial
Classification
(
SIC)
Codes
For
the
printer's
data
collection,
respondents
will
be
employed
in
printing
facilities.
Community
members
to
be
surveyed
are
expected
to
represent
the
general
public
and
are
not
associated
with
a
particular
business
sector.

Parts
of
the
following
SIC
codes
will
be
affected
by
this
evaluation:
°
SIC
code
27
­
Printing
and
Publishing
°
SIC
code
2396
­
Automotive
Trimmings,
Apparel
Findings
and
Related
Articles
(
e.
g.,
printing
and
embossing
on
fabric
articles)
°
SIC
code
3999
­
Manufacturing
Industries,
Not
Elsewhere
Classified
(
e.
g.,
printing
of
eyeglass
frames).

4(
b)
Information
Requested
Full
details
of
the
evaluation
are
described
in
the
PrintSTEP
Evaluation
Strategy,
attached
as
Appendix
A.
The
Evaluation
Strategy
was
developed
in
close
consultation
and
with
significant
input
from
the
PrintSTEP
stakeholder
representative
group.
This
group
included
representatives
of
the
parties
from
whom
the
information
is
to
be
obtained,
namely
printers
and
community
members.
Additionally,
state
environmental
agencies
and
environmental
justice
representatives
Page
6
were
included
in
this
group.
The
group
was
involved
with
designing
the
evaluation
strategy
and
data
collection
instruments,
ensuring
that:
the
environmental
benefit
of
the
pilot
is
thoroughly
tracked;
the
data
collection
instruments
are
technically
sound;
the
instructions
are
clear;
the
terminology
is
coherent,
unambiguous,
and
understandable
to
respondents;
respondent
burden
is
minimized;
and
the
data
is
obtainable,
but
has
not
been
collected
previously.
The
research
approach
was
designed
to
minimize
respondent
burden
as
well
as
to
minimize
data
collection
costs
to
the
government.
The
information
collection
described
in
the
Evaluation
Strategy
includes:

°
Background
questionnaire
for
printers.
In
Minnesota
and
New
Hampshire,
the
PrintSTEP
pilot
coordinators
will
send
a
questionnaire
to
printers
to
assist
in
identifying
the
universe
of
printers
in
the
pilot
implementation
area
who
may
ultimately
be
subject
to
the
evaluation.
The
questionnaire
will
ask
for
the
following
information:
company
name,
contact
person,
mailing
address,
facility
address,
type
of
printing
process
operated,
type
of
printing
jobs,
and
whether
or
not
the
printer
would
possibly
be
interested
in
joining
PrintSTEP.
A
space
for
comments
will
also
be
included.
The
questionnaire
will
be
printed
as
a
tri­
fold
with
postage­
paid
return
address.
The
PrintSTEP
coordinator
for
these
pilot
states
will
receive
the
responses
and
will
use
them
to
build
and/
or
enhance
their
database
of
potentially
interested
printers
who
may
be
subject
to
the
evaluation.
°
Telephone
survey
of
PrintSTEP
printers.
All
printers
who
volunteer
to
participate
in
the
pilot
project
("
PrintSTEP
printers")
will
be
contacted
to
complete
a
telephone
survey
(
attached
as
Appendix
B)
at
three
times
during
the
pilot
project.
Upon
joining,
an
initial
survey
will
establish
the
baseline
environmental
status
and
public
involvement
history
of
these
printers.
An
interim
survey
will
be
conducted
mid­
way
through
the
pilot,
and
a
postpilot
survey
will
be
conducted
at
the
conclusion
of
the
pilot
project.
°
Telephone
survey
of
comparison
printers.
A
group
of
printers
who
are
not
participating
in
PrintSTEP
will
be
identified
in
each
pilot
state
to
serve
as
a
comparison
group.
Collecting
comparable
information
from
these
printers
will
enable
EPA
to
determine
if
the
environmental
changes
of
the
PrintSTEP
printers
can
be
attributed
to
the
PrintSTEP
program
or
if
such
changes
would
have
occurred
without
PrintSTEP.
After
the
PrintSTEP
application
period
is
closed,
the
comparison
group
will
be
identified
and
contacted
for
an
initial
telephone
interview
to
establish
their
baseline
environmental
status
and
public
involvement
history.
The
questions
used
in
this
interview
are
similar
to
those
asked
of
the
PrintSTEP
printers,
as
detailed
in
the
survey
instrument
(
Appendix
B).
As
with
the
PrintSTEP
printers,
the
comparison
group
will
also
be
interviewed
via
telephone
survey
again
at
the
mid­
point
and
conclusion
of
the
pilot
project.
°
Written
information
from
PrintSTEP
printers.
The
pilot
states
will
collect
information
on
the
PrintSTEP
printers'
environmental
releases
and
wastes
from
PrintSTEP
applications
that
printers
submit
when
joining
PrintSTEP.
Printers
will
also
provide
annual
updates
of
this
information
to
the
state.
For
many
printers,
this
application
will
replace
the
separate
applications
they
filled
out
in
the
past
for
each
media
program
(
air,
water,
hazardous
waste,
and
storm
water).
A
sample
application
template
is
attached
as
Appendix
C.
The
application
includes
quantitative
information
such
as
quantity
and
type
of
hazardous
waste
generated
annually,
pounds
or
gallons
of
VOC­
containing
and
HAP­
Page
7
containing
materials
used
per
year,
and
pollution
prevention
practices
employed.
Also,
printers
record
an
indicator
of
their
level
of
production
(
e.
g.,
sales,
square
feet
of
printed
material,
etc.)
so
that
changes
in
environmental
impact
related
to
changes
in
production
can
be
accounted
for
in
the
analysis.
To
evaluate
whether
or
not
PrintSTEP
is
more
costeffective
for
printers
than
the
traditional
regulatory
process,
additional
written
information
regarding
the
costs
of
participating
in
PrintSTEP
will
be
collected
as
a
fax­
back
or
emailback
form
following
the
telephone
interview.
A
sample
fax­
back
form
is
included
as
Appendix
F.
°
Written
information
from
comparison
printers.
As
non­
participants,
the
comparison
group
will
not
be
submitting
a
PrintSTEP
application.
However,
similar
information
on
their
environmental
releases
and
wastes
is
needed
to
determine
if
environmental
changes
in
the
PrintSTEP
printers
can
actually
be
attributed
to
the
PrintSTEP
program.
At
the
conclusion
of
the
telephone
survey,
each
comparison
printer
will
be
asked
to
submit
written
information
equivalent
to
the
information
collected
on
the
PrintSTEP
application.
A
form
will
be
emailed
or
faxed
to
the
respondent.
It
will
also
include
questions
related
to
the
costs
associated
with
environmental
activities
(
see
Appendices
C
and
F).
This
information
will
be
collected
and
entered
into
a
database
by
the
states.
°
Telephone
survey
of
community
members.
The
community's
experience
with
the
PrintSTEP
pilot
will
be
evaluated
through
a
telephone
survey
conducted
approximately
mid­
way
through
the
pilot
project.
The
states
will
conduct
this
survey.
For
community
members,
information
will
be
collected
on
how
they
became
aware
of
PrintSTEP,
in
what
ways
they
participated,
and
how
effective
they
felt
their
participation
was.
The
survey
instrument
for
community
members
is
attached
in
Appendix
D.

5.
THE
INFORMATION
COLLECTED
­
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
5(
a)
Agency
Activities
The
EPA
will
be
responsible
for
directing
the
work
of
the
survey
research
contractor
for
the
data
collection
and
analysis.
The
Agency
will
also
facilitate
the
transfer
of
data
from
the
pilot
states
to
the
contractor,
as
the
states
are
providing
EPA
with
the
database
of
written
data
collected,
coded
by
facility
identification
code,
rather
than
facility
name.

5(
b)
Collection
Methodology
and
Management
PrintSTEP
program
participants
will
be
volunteers.
They
will
be
identified
by
each
state
through
outreach,
assisted
in
part
by
local
trade
associations.
For
the
evaluation,
a
comparison
group
will
also
be
identified
of
non­
participating
printers.
They
will
be
identified
by
the
states
with
close
cooperation
with
or
directly
through
the
trade
associations.
In
Missouri,
the
pilot
will
be
implemented
only
in
the
St.
Louis
area.
In
Minnesota,
it
will
be
implemented
only
in
the
St.
Cloud
area.
For
these
two
states,
the
comparison
group
will
likely
be
drawn
from
printers
in
other
parts
of
the
state
who
would
have
volunteered
for
PrintSTEP
if
the
opportunity
had
been
available
to
them.
The
printing
trade
associations
will
assist
in
identifying
the
printers
that
would
be
likely
to
volunteer
for
a
PrintSTEP
program,
and
who
are
similar
to
the
group
of
participating
Page
8
printers
in
characteristics
such
as
environmental
impact,
type
of
printing
processes
used,
and
size
of
facility.
In
New
Hampshire,
the
pilot
is
being
implemented
statewide.
The
state
PrintSTEP
coordinator
will
work
closely
with
the
printing
trade
associations
to
identify
an
appropriate
comparison
group.

Community
participants
in
the
evaluation
will
be
selected
from
lists
of
community
members
who
submitted
comments,
attended
meetings,
or
otherwise
participated
in
the
PrintSTEP
process.
A
comparison
group
of
community
members
will
not
be
used
because
there
is
no
comparable
public
involvement
process
currently
in
existence
to
which
PrintSTEP
can
be
compared.
Collecting
information
about
public
involvement
in
environmental
regulatory
activities
in
general
would
constitute
a
much
larger
study,
separate
in
its
scope
from
the
evaluation
of
PrintSTEP.

The
printers'
survey
will
be
conducted
using
Computer
Assisted
Telephone
Interviewing
(
CATI)
by
experienced
interviewers.
The
CATI
programs
move
the
interviewer
swiftly
and
accurately
through
skip
patterns
within
the
instrument.
This
technique
was
selected
as
the
most
costeffective
means
to
minimize
data
processing
time
and
data
entry
errors,
to
reduce
the
burden
on
the
respondents
by
reducing
the
length
of
the
call,
and
to
reduce
the
need
for
follow­
up
calls.
Currently,
printers
have
not
yet
been
recruited
for
the
pilot
project,
therefore,
it
was
not
possible
to
conduct
an
actual
pretest
of
the
survey.
However,
a
review
of
the
survey
instruments
by
the
survey
research
contractor
to
EPA
indicates
that
the
printer's
survey
will
take
approximately
12
minutes.

Additionally,
written
information
on
environmental
releases
and
wastes,
and
costs
of
meeting
environmental
regulatory
requirements
will
be
collected
from
the
comparison
group
via
an
email
or
fax­
back
form.
Only
cost
information
will
be
collected
from
the
PrintSTEP
printers
by
this
method
(
the
rest
of
the
written
data
from
participating
printers
will
be
submitted
to
state
agencies
as
a
routine
part
of
the
PrintSTEP
program).
At
the
conclusion
of
the
telephone
interview,
the
interviewer
will
explain
the
written
information
required
and
will
email
or
fax
the
form
to
the
respondent.
This
method
will
simplify
the
return
process
for
the
respondent.
Entry
and
coding
of
written
portions
will
be
done
by
the
states,
and
entry
and
coding
of
the
telephone
survey
will
be
done
by
the
survey
research
firm
contracted
by
EPA.

This
combination
of
telephone
survey
and
written
information
was
considered
the
least
burdensome
for
facilities
without
losing
the
reliability
or
accuracy
of
the
information
collected.
The
telephone
survey,
which
is
expected
to
last
approximately
12
minutes,
focuses
on
collecting
the
more
subjective
information.
Quantitative
information
is
collected
in
written
format
for
convenience
(
fax­
back
or
email­
back)
and
accuracy
(
the
respondent
may
have
to
consult
with
their
records
or
coworkers
to
answer
these
questions).

The
telephone
survey
of
community
participants
will
be
conducted
by
the
pilot
states.
States
will
also
be
responsible
for
entering
and
coding
these
data.
All
survey
results
will
be
compiled
and
analyzed
into
a
final
report
by
the
EPA
contractor
conducting
the
printer
survey.

5(
c)
Small
Entity
Flexibility
Page
9
Respondents
in
the
proposed
data
collection
will
include
large
printing
establishments
as
well
as
small
establishments
located
in
PrintSTEP
pilot
areas.
Printers
of
every
size
are
allowed
to
participate
in
the
program,
and
surveying
the
printers
is
the
only
way
to
obtain
information
that
is
representative
of
the
effectiveness
of
PrintSTEP.
The
information
obtained
from
all
of
these
businesses,
and
a
comparable
comparison
group,
is
critical
in
evaluating
the
PrintSTEP
program.
Every
effort
has
been
made
to
minimize
the
burden
on
respondents.
Specifically,
respondent
burdens
for
small
entities
(
and
all
other
respondents)
will
be
minimized
in
the
following
ways:

°
The
survey
was
designed
to
be
brief
(
12
minutes)
by
asking
a
limited
set
of
questions
which
focus
on
only
the
pertinent
issues
of
the
evaluation.
°
The
questions
in
the
survey
only
ask
for
information
that
cannot
be
obtained
from
other
sources.
°
The
survey
will
be
conducted
using
Computer
Assisted
Telephone
Interviewing
(
CATI)
by
experienced
interviewers.
The
CATI
programs
move
the
interviewer
swiftly
and
accurately
through
skip
patterns
within
the
instrument,
reducing
errors
and
the
need
for
follow­
up
calls.

5(
d)
Collection
Schedule
Information
collection
requested
by
EPA
will
begin
upon
approval
of
the
ICR
and
after
the
PrintSTEP
application
deadline.
Participating
printers
will
be
interviewed
three
times
during
the
PrintSTEP
pilot.
Within
two
months
of
volunteering,
printers
will
be
interviewed
as
part
of
the
baseline
data
collection.
Following
approval
of
their
application,
a
follow
up
interview
will
be
conducted,
largely
focused
on
their
public
involvement
activities.
A
final
interview
will
be
conducted
at
the
conclusion
of
the
pilot
project,
which
is
not
more
than
three
years
after
printer
recruitment.
The
comparison
group
of
printers
will
be
interviewed
three
times
as
well:
after
the
PrintSTEP
application
deadline,
approximately
one
year
after
that,
and
at
the
end
of
the
pilot
project.

Data
will
be
collected
from
community
participants
once
during
the
pilot
program.
Interviews
will
be
conducted
during
the
two
months
following
the
community
members'
involvement
in
the
PrintSTEP
public
participation
activities
for
any
given
printer.
It
is
not
possible
to
interview
community
members
before
the
pilot
(
to
gather
baseline
data),
because
there
is
no
way
of
knowing
who
will
later
become
a
participant
in
PrintSTEP.

An
interim
report
will
be
completed
two
months
following
the
completion
of
the
mid­
point
data
collection.
A
final
report
will
be
completed
within
two
months
of
completing
the
post­
pilot
data
collection.
These
reports
will
include
an
analysis
of
the
results
from
the
information
collected
from
printers,
community
members,
and
the
pilot
states.

6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
6(
a)
Respondent
Burden
The
PrintSTEP
evaluation
includes
a
telephone
interview
with
three
types
of
respondents:
1)
Page
10
printers
who
are
voluntarily
participating
in
the
PrintSTEP
program;
2)
a
volunteer
comparison
group
of
printers
who
are
not
participating
in
PrintSTEP;
and
3)
community
members
who
have
participated
in
the
public
involvement
component
of
PrintSTEP.
For
the
PrintSTEP
printers,
written
data
will
be
collected
detailing
the
costs
of
participating
in
the
PrintSTEP
program..
For
the
non­
participating,
comparison
group
printers,
written
data
will
be
collected
detailing
the
costs
of
meeting
their
regulatory
requirements
in
the
traditional
system.
For
the
comparison
group
of
printers,
additional
written
data
will
be
collected
on
environmental
releases
and
wastes.
It
is
anticipated
that
a
total
of
175
printers
will
apply
to
participate
in
PrintSTEP
across
the
three
pilot
states.
The
Evaluation
Strategy
calls
for
a
census,
rather
than
a
sample
of
these
printers.
Justification
for
this
approach
is
presented
in
the
Evaluation
Strategy
(
Appendix
A)
and
in
Part
B
of
this
ICR.
Assuming
a
90%
response
rate,
interviews
will
be
conducted
with
158
printers.
The
evaluation
will
also
attempt
to
recruit
a
comparably­
sized
comparison
group
of
printers.
Combined,
it
is
anticipated
that
approximately
316
printers
will
be
interviewed
three
times
during
the
course
of
the
evaluation
and
that
the
person
interviewed
will
be
an
environmental
professional.
It
is
anticipated
that
175
community
members
will
participate
in
PrintSTEP
across
the
three
pilot
states.
Assuming
a
75%
response
rate,
131
community
members
will
be
interviewed.

The
telephone
portion
of
the
printer's
survey
is
expected
to
take
approximately
12
minutes
to
complete.
The
written
information
on
environmental
releases
and
wastes,
plus
cost
information,
is
expected
to
take
2.75
hours
for
printers
to
complete.
For
PrintSTEP
printers,
this
environmental
release
information
will
be
collected
by
the
states
through
the
PrintSTEP
applications.
The
state
background
questionnaire
for
printers
is
expected
to
take
approximately
12
minutes
to
complete.
It
is
estimated
that
700
facilities
will
respond
(
assuming
a
maximum
response
rate
of
50%).
The
telephone
interview
with
community
members
is
expected
to
take
15
minutes.
The
estimates
of
respondent
burden
are
shown
in
the
table
below.

Respondent
Type
Estimated
number
of
respondents
Time
to
complete
state
background
questionnaire
Time
to
respond
to
telephone
survey
(
hrs)
1
Time
to
complete
written
response
(
hrs)
1
Total
respondent
burden
(
hrs)

Year
1
(
baseline)

Printers
responding
to
state
mailing
700
0.2
na
na
140
PrintSTEP
printer
158
0.2
2.75
466
Comparison
printer
158
0.2
2.75
466
Year
2
PrintSTEP
printer
158
0.2
2.75
466
Comparison
printer
158
0.2
2.75
466
Community
member
131
0.25
0.00
33
Year
3
PrintSTEP
printer
158
0.2
2.75
466
Comparison
printer
158
0.2
2.75
466
Total
for
all
3
years
2969
1
Estimate
based
on
preliminary
review
of
the
survey
instruments
by
Abt
Associates.
Page
11
6(
b)
Respondent
Costs
The
PrintSTEP
evaluation
utilizes
the
telephone
interviews
and
written
data
collection
forms
to
collect
all
the
data
necessary
from
the
respondent.
There
are
no
capital,
operations,
or
maintenance
costs
associated
with
this
information
collection.
At
this
time,
it
is
assumed
that
no
payment
or
gift
will
be
provided
to
respondents.
If
the
pilot
states
find
that
recruiting
a
comparison
group
of
printers
is
difficult,
a
gift
of
less
than
five
dollars
in
value
may
be
considered
(
e.
g.,
pen,
coupon).
The
only
cost
to
the
respondents
resulting
from
this
survey
is
their
time,
as
shown
in
the
table
below.

Respondent
Type
Estimated
number
of
respondents
Time
to
respond
to
information
request
(
hr/
printer)
1
Total
respondent
burden
(
hrs)
Estimated
avg.
compensation
of
respondent
($/
hr)
2
Total
respondent
burden
in
monetary
terms
($)

Year
1
(
baseline)

Printers
responding
to
state
mailing
700
0.2
140
$
28.59
$
4,003
PrintSTEP
printer
158
2.95
466
$
28.59
$
13,326
Comparison
printer
158
2.95
466
$
28.59
$
13,326
Year
2
PrintSTEP
printer
158
2.95
466
$
28.59
$
13,326
Comparison
printer
158
2.95
466
$
28.59
$
13,326
Community
member
131
0.25
33
$
21.16
$
693
Year
3
PrintSTEP
printer
158
2.95
466
$
28.59
$
13,326
Comparison
printer
158
2.95
466
$
28.59
$
13,326
Total
for
all
3
years
$
84,650
1
Estimate
based
on
preliminary
review
of
the
survey
instruments
by
Abt
Associates.
2
Compensation
data
is
from
the
U.
S.
Department
of
Labor's
Bureau
of
Labor
Statistics'
Employer
Costs
for
Employee
Compensation
Summary
­
March
2000.
Printers'
compensation
from
Table
12,
compensation
for
employees
in
manufacturing,
white­
collar,
technical
occupations.
Community
member
compensation
from
Table
1,
compensation
for
civilian
workers
(
private
industry
and
State
and
local
government).
Compensation
includes
wages
and
salaries,
and
benefits
(
paid
leave,
supplemental
pay,
insurance,
retirement
and
savings,
and
legally
required
benefits).

6(
c)
Estimating
Agency
Burden
and
Cost
The
total
contracted
cost
to
the
federal
government
under
contract
68­
W6­
0021
for
project
planning
and
management,
development
of
research
design
and
data
collection
instruments
was
$
83,700.
Additional
contract
cost
will
be
incurred
for
conducting
phone
surveys
to
printers,
preparation
of
data
files,
and
analysis
and
reporting
of
results.
In
addition,
the
three
pilot
states
will
fund
several
activities,
including
the
telephone
survey
for
the
community
participants,
sending
advance
letters
to
printers
about
the
evaluation,
follow
up
with
the
comparison
group
of
printers
for
the
written
portion,
and
entry
and
coding
of
the
written
portion
of
the
data
collection
for
all
printers.
Page
12
6(
e)
Reasons
for
Change
in
Burden
This
is
a
new
data
collection
effort,
therefore
this
section
is
not
applicable.

6(
f)
Burden
Statement
It
is
estimated
that
approximately
175
printers
may
voluntarily
participate
in
PrintSTEP
over
the
course
of
the
pilot
program,
and
that
158
will
be
interviewed
as
part
of
this
information
collection.
It
is
estimated
that
each
printer
will
spend
2.95
hours
per
year
($
84.34)
or
a
total
of
8.85
hours
($
253.02)
over
three
years
to:
°
respond
to
the
annual
telephone
survey;
°
complete
the
fax­
back
form
on
their
costs
associated
with
their
environmental
requirements
(
i.
e.,
PrintSTEP
requirements
for
participants
and
traditional
regulatory
requirements
for
the
comparison
group);
and
°
document
their
environmental
releases
and
wastes
(
i.
e.,
on
the
PrintSTEP
application
for
participants
or
on
an
equivalent
form
for
the
comparison
group).

Each
of
the
participating
community
members
interviewed
is
expected
to
spend
15
minutes
($
5.29)
responding
to
the
one­
time
telephone
survey.
No
other
information
collection
is
expected
from
this
respondent
group.

PART
B
OF
THE
SUPPORTING
STATEMENT
1.
SURVEY
OBJECTIVES,
KEY
VARIABLES,
AND
OTHER
PRELIMINARIES
1(
a)
Survey
Objectives
Details
of
the
survey
objectives
and
how
they
contribute
to
the
overall
PrintSTEP
evaluation
are
described
in
the
PrintSTEP
Evaluation
Strategy
(
Appendix
A).
Key
points
of
the
strategy
are
summarized
here.

Because
PrintSTEP
is
a
multifaceted
program,
it
has
a
variety
of
goals.
The
PrintSTEP
Project
Team
has
identified
seven
types
of
expected
outcomes,
each
of
which
has
several
component
parts.


enhanced
environmental
protection;


increased
use
of
pollution
prevention
practices;


simplified
regulatory
process
for
printers;


improved
efficiency
of
administration
for
state
governments;


enhanced
public
involvement;


participants
realize
benefits
and
are
motivated
to
participate
in
PrintSTEP;
and

cost
effectiveness
for
all
stakeholders.

This
broad
set
of
expected
outcomes
will
require
a
range
of
distinct
data
collection
and
analysis
activities.
Data
will
be
gathered
from
printer's
program
applications
and
telephone
interviews.
Data
will
be
collected
before
implementation,
mid­
way
through
the
pilot
program,
and
at
the
end
of
the
pilot.
A
key
feature
of
the
recommended
design
is
the
use
of
a
comparison
group
of
Page
13
printers
as
a
tool
for
gauging
the
impact
of
the
PrintSTEP
program.
The
specific
data
collection
activities
are
described
below.

Printers:
Telephone
Survey
and
PrintSTEP
Application
Forms
It
is
critical
to
the
evaluation
to
understand
how
printers
view
the
PrintSTEP
program,
how
the
costs
of
participating
compare
to
the
costs
of
not
participating,
and
what
changes
participating
printers
have
made
as
a
result
of
their
participation
in
the
program.
Both
participating
and
nonparticipating
printers
will
be
interviewed
by
telephone
three
times:
before
the
program
is
implemented,
midway
through
the
pilot,
and
at
the
end
of
the
pilot.
The
initial
interview
will
provide
baseline
data.
The
baseline
survey
establishes
a
starting
point
against
which
subsequent
measures
can
be
compared.
The
interim
survey
focuses
on
the
printers'
opinions
about
the
public
involvement
process
and
the
initial
application
process
and
about
the
costs
they
incurred
as
part
of
these
processes.
This
information
is
likely
to
be
more
accurate
if
collected
at
an
interim
point
than
it
would
be
if
it
were
collected
at
the
end
of
the
pilot.
The
post­
pilot
survey
concentrates
on
changes
to
the
production
process
and
measures
of
environmental
impact
­­
areas
where
any
impacts
are
not
likely
to
be
fully
evident
earlier
in
the
program.
The
survey
instruments
for
each
of
these
three
stages,
or
"
waves,"
is
included
as
Appendix
B.

The
telephone
survey
will
be
combined
with
written
information
from
the
PrintSTEP
application
(
or
an
equivalent
form
for
the
comparison
group),
to
collect
the
data
needed.
The
PrintSTEP
application
form
and
annual
updates
will
complement
the
telephone
interviews
by
providing
written
data
on
environmental
releases
before
and
after
pilot
implementation.
The
application
template
as
it
appears
in
the
PrintSTEP
Plain
Language
Workbook
may
be
modified
to
capture
the
relevant
data.
Printers
will
complete
the
application
when
they
first
volunteer
for
PrintSTEP
and
then
will
update
their
application
annually.
See
Appendix
C
for
an
example
of
a
PrintSTEP
Application
template.
Information
on
costs
incurred
related
to
PrintSTEP
or
traditional
environmental
regulation
will
be
collected
via
an
email
or
fax­
back
form
that
will
be
sent
to
the
printer
at
the
completion
of
the
telephone
interview
(
see
Appendix
F).
An
EPA
contractor
will
conduct
the
telephone
survey
of
participating
printers
and
the
comparison
group
of
printers.
The
written
data
on
the
PrintSTEP
applications
will
be
collected
by
the
pilot
states
as
part
of
the
PrintSTEP
process.

Community
Residents:
Telephone
Survey
Each
pilot
state
is
responsible
for
evaluating
the
experience
of
community
participants
in
PrintSTEP
through
telephone
interviews.
To
collect
this
information
consistently
among
the
three
pilot
states,
a
survey
instrument
has
been
developed
and
reviewed
by
the
PrintSTEP
team's
stakeholders
(
see
Appendix
D).
Community
residents
participating
in
PrintSTEP
will
be
interviewed
after
the
public
involvement
process
for
the
printer
with
whom
they
are
involved
is
complete.
Community
members
participating
in
PrintSTEP
will
be
identified
from
the
lists
associated
with
the
PrintSTEP
Registry,
PrintSTEP
Information
Repository
and
public
meetings.
Interviews
will
collect
information
about
the
effectiveness
of
notice,
access
to
information,
ability
to
comment
effectively,
and
the
overall
effectiveness
of
participation,
and
related
improvements
that
result.
Page
14
1(
b)
Key
Variables
Key
variables,
described
in
the
PrintSTEP
Evaluation
Strategy
(
Appendix
A)
include:
the
ease
in
completing
the
PrintSTEP
application;
the
use
of
the
technical
assistance
available
to
PrintSTEP
participants;
the
level
of
interest
in
implementing
pollution
prevention
practices;
and
the
level
of
public
involvement
for
each
printer.

1(
c)
Statistical
Approach
A
census
will
be
conducted,
therefore
this
section
is
not
relevant.

1(
d)
Feasibility
It
is
not
anticipated
that
the
printers
or
community
members
will
have
any
problems
or
delays
answering
the
questions
in
the
telephone
survey
portion
of
the
data
collection.
To
complete
the
written
application,
the
printers
will
have
extensive
guidance
available
to
them,
including
the
PrintSTEP
Plain
Language
Workbook
which
gives
step­
by­
step
instructions
and
examples.
They
will
also
have
access
to
technical
assistance
by
phone
provided
by
each
of
the
pilot
states.
The
pretest
will
specifically
ask
for
feedback
on
the
ease
of
completing
the
printers'
fax­
back
form
on
costs.
If
additional
instructions
are
needed
(
beyond
what
is
provided
on
the
form
itself),
such
guidance
will
be
developed
and
included
with
the
form.

The
greatest
obstacle
anticipated
in
this
information
collection
is
in
recruiting
the
volunteer
printers
for
the
comparison
groups
in
each
state.
While
there
are
few
incentives
for
these
printers
to
participate,
the
local
printing
trade
associations
have
agreed
to
assist
with
the
recruitment
efforts.
The
state
PrintSTEP
coordinators
do
not
foresee
recruitment
problems
for
the
comparison
groups
in
Minnesota
and
Missouri
where
the
pilot
project
will
be
implemented
in
a
limited
geographic
area.
In
these
states,
the
comparison
groups
will
be
recruited
from
parts
of
the
state
outside
the
pilot
area.
New
Hampshire,
however,
is
implementing
the
PrintSTEP
pilot
statewide.
Recruitment
of
a
comparison
group
of
printers
in
this
state
will
be
more
challenging
because
all
printers
in
the
state
are
eligible
to
join
the
pilot.
The
comparison
group
will
consist
of
printers
who
chose
not
to
join
PrintSTEP
and
therefore,
this
comparison
group
may
be
biased.
Working
closely
with
the
trade
association,
the
state
will
recruit
this
comparison
group.
The
analysts
evaluating
the
data
will
examine
the
characteristics
of
the
comparison
group
to
insure
that
biases
in
this
group
are
recognized
and
accounted
for
in
the
analysis.

The
final
program
evaluation
analysis
will
be
available
two
months
after
the
conclusion
of
the
pilot
program.
Interim
results
will
be
available
thirty
days
after
the
conclusion
of
the
interim
data
collection.
This
schedule
provides
sufficient
time
for
the
program's
decision­
making
needs
regarding
future
expansion
of
the
PrintSTEP
program.

2.
SURVEY
DESIGN
2(
a)
Target
Population
and
Coverage
The
population
of
interest
for
this
evaluation
is
printers
participating
in
the
PrintSTEP
pilot
program.
It
is
estimated
that
a
total
of
175
printers
will
participate
in
the
program.
For
such
a
Page
15
small
population,
a
census
is
considered
most
appropriate
in
producing
robust,
defensible,
results.
Additionally,
a
census
will
eliminate
errors
associated
with
a
skewed
sampling
response.
If
a
sampling
approach
were
used
instead,
it
would
be
important
to
make
sure
the
sample
represented
differences
among
the
three
pilot
states,
the
different
types
of
printing
processes
(
e.
g.,
lithography,
screen
printing),
and
different
size
facilities.
The
population
is
not
large
enough
to
be
stratified
to
include
all
these
relevant
subpopulations
and
still
draw
a
meaningful
sample.
Therefore,
the
evaluation
design
proposed
includes
a
census
of
volunteer
participants.
The
anticipated
response
rate
for
printers
is
90%
(
158
completed
interviews).
All
of
these
printers
will
be
participating
in
PrintSTEP
voluntarily
and
will
be
informed
of
the
requirements
of
the
evaluation
prior
to
volunteering
for
the
program.
An
additional
158
non­
participating
printers
will
be
interviewed
as
a
comparison
group.
These
printers
will
be
volunteers
identified
by
each
pilot
state
through
trade
associations
and
state
contacts.

Community
members
who
voluntarily
participate
in
PrintSTEP
will
be
interviewed
by
phone
at
one
time
during
the
pilot.
Again,
there
are
several
subpopulations
of
interest
including
community
members
in
the
three
different
states
and
those
working
with
different
types
and
sizes
of
printing
facilities.
Therefore,
a
census
of
participating
community
members
is
proposed.
It
is
anticipated
that
175
community
members
will
participate
and
all
will
be
contacted.
A
response
rate
of
75%
is
estimated
for
this
group
(
131
completed
interviews).

2(
b)
Sample
Design
As
described
above,
a
census,
rather
than
a
sample,
of
all
participants
will
be
conducted.

2(
c)
Precision
Requirements
Because
a
census
will
be
conducted,
any
differences
or
similarities
among
values
are
actual
and
not
due
to
the
chance
selection
of
a
non­
representative
subpopulation
for
a
survey
sample.
Potential
for
bias
still
exists,
however.
If
there
are
significant
differences
between
the
respondent
population
and
non­
respondents,
then
the
survey
results
may
not
accurately
reflect
the
opinions
and
activities
of
all
participants.

To
determine
the
extent
of
respondent
bias
in
the
survey
results,
the
respondent
and
nonrespondent
populations
will
be
compared
on
several
criteria:
type
of
printing
process,
size
of
facility,
and
baseline
(
i.
e.,
pre­
PrintSTEP)
regulatory
requirements.
If
there
is
no
statistical
difference
in
these
factors
between
the
respondents
and
non­
respondents,
respondent
bias
in
the
survey
would
be
considered
unlikely,
although
the
possibility
of
bias
from
other
unexamined
factors
always
remains.

Steps
will
also
being
taken
to
minimize
another
type
of
bias,
known
as
strategic
responses.
Strategic
responses
occur
where
respondents
alter
their
answers
in
an
attempt
to
influence
conclusions
drawn
from
the
survey
overall
or
from
their
response
in
particular.
Strategic
response
can
be
particularly
problematic
if
respondents
perceive
that
the
survey
outcome
may
directly
alter
regulatory
requirements.
To
reduce
bias
and
strategic
responses,
interviewers
will:
provide
context
for
the
survey,
guarantee
anonymity,
use
neutral
wording,
use
open
ended
questions
(
these
will
be
limited
to
maintain
cost­
effectiveness
of
the
survey),
and
rotate
the
order
of
the
Page
16
response
prompts
(
to
avoid
predisposition
to
selection
of
the
first
or
last
prompts).

2(
d)
Questionnaire
Design
The
survey
instruments
were
developed
by
Abt
Associates
Inc.,
under
U.
S.
EPA
contract
68­
W6­
0021.
The
work
was
done
with
close
consultation
and
significant
input
from
U.
S.
EPA
and
the
PrintSTEP
stakeholder
representative
group.
This
group
included
representatives
of
the
parties
from
whom
the
information
is
to
be
obtained,
namely
printers
and
community
members.
This
group
was
directly
involved
with
designing
the
evaluation
strategy
and
data
collection
instruments,
ensuring
that:
the
environmental
benefit
of
the
pilot
is
thoroughly
tracked;
the
data
collection
instruments
are
technically
sound;
the
instructions
are
clear;
the
terminology
is
coherent,
unambiguous,
and
understandable
to
respondents;
respondent
burden
is
minimized;
and
the
data
is
obtainable,
but
has
not
been
collected
previously.
Additionally,
the
contractor's
survey
research
professionals
reviewed
the
survey
instruments
to
check
that
items
are
unambiguous,
unbiased,
nonrepetitive,
and
properly
sequenced,
skip
patterns
are
clear,
and
answer
categories
are
mutually
exclusive
and
collectively
exhaustive.

The
survey
instruments
are
attached
as
Appendix
B
(
Survey
Instruments
for
Printers)
and
Appendix
D
(
Survey
Instrument
for
Community
Members).

3.
PRETESTS
AND
PILOT
TESTS
The
printer's
survey
instrument
will
be
subject
to
a
pretest
at
the
contractor's
Survey
Research
Center.
The
pretest
is
conducted
to
verify
the
survey
instrument
will
collect
all
of
the
data
required
to
meet
the
objectives
of
the
survey
in
the
most
efficient
manner.
The
entire
draft
survey
will
be
administered
to
nine
facilities
randomly
selected
from
the
list
of
participating
printers.

The
survey
of
community
members
will
be
administered
by
the
pilot
states,
each
state
will
use
the
survey
instrument
developed
by
the
stakeholder
group
(
Appendix
D).
This
survey
instrument
will
also
be
pretested
prior
to
the
final
release
to
states.
For
the
pretest,
the
draft
survey
will
be
administered
to
nine
community
members
randomly
selected
from
the
list
of
community
members
who
participated
in
the
PrintSTEP
process.

Pretest
interviews
will
be
timed,
and
respondents
will
be
asked
to
comment
on
the
instrument.
Each
interviewer
will
propose
changes
in
the
instrument.
These
changes
will
be
reviewed
with
EPA
and
if
the
changes
can
minimize
burden,
clarify
wording,
or
improve
utility,
questions
will
be
modified.
If
modifications
are
considered
minor,
results
from
the
pretest
will
be
included
in
the
final
survey
results
and
the
pretest
respondents
would
not
need
to
be
interviewed
again.

4.
COLLECTION
METHODS
AND
FOLLOW­
UP
4(
a)
Collection
Methods
The
printers'
survey
will
be
conducted
using
Computer
Assisted
Telephone
Interviewing
(
CATI)
by
experienced
interviewers.
The
CATI
programs
move
the
interviewer
swiftly
and
accurately
Page
17
through
skip
patterns
within
the
instrument.
This
technique
was
selected
as
the
most
costeffective
means
to
minimize
data
processing
time
and
data
entry
errors,
and
to
reduce
the
burden
on
the
respondents
by
reducing
the
length
of
the
call,
and
the
need
for
follow­
up
calls.
Currently,
printers
have
not
yet
been
recruited
for
the
pilot
project,
therefore,
it
was
not
possible
to
conduct
an
actual
pretest
of
the
survey.
Review
of
the
survey
instruments
by
a
survey
research
contractor
indicates
that
the
printer's
survey
will
take
approximately
12
minutes.

Additionally,
written
information
on
environmental
impacts
and
costs
will
be
collected
from
the
comparison
group
via
an
email
or
fax­
back
form.
Only
cost
information
will
be
collected
from
the
PrintSTEP
printers
by
this
method
(
the
rest
of
the
written
data
from
participating
printers
will
be
submitted
to
state
agencies
as
a
normal
part
of
the
PrintSTEP
program).
The
interviewer
will
explain
the
written
information
required
during
the
interview
and
will
email
or
fax
the
form
to
the
respondent.
This
method
will
simplify
the
return
process
for
the
respondent.
Entry
and
coding
of
written
portions
will
be
done
by
the
states,
and
entry
and
coding
of
the
telephone
survey
will
be
done
by
the
survey
research
firm.

This
combination
of
telephone
survey
and
written
information
was
considered
the
least
burdensome
for
facilities
without
losing
the
reliability
or
accuracy
of
the
information
collected.
The
telephone
survey
is
expected
to
last
less
than
15
minutes
and
it
focuses
on
collecting
the
more
subjective
information.
Quantitative
information
is
collected
in
a
written
format
for
convenience
(
fax­
back
or
email­
back)
and
accuracy
(
the
respondent
may
have
to
consult
with
their
records
or
coworkers
to
complete
answer
these
questions).
Data
collection
procedures
also
include:
Interviewer
requirements/
training.
The
contractor's
interviewing
staff
come
from
a
variety
of
backgrounds
and
are
hired
based
on
their
verbal
skills,
knowledge
and
experience
with
computers,
work
experience
related
to
survey
research,
and
attention
to
detail.
Interviewers
attend
basic
training
that
covers
all
aspects
of
standard
interviewing
practices,
including
verbatim
reading,
refusal
aversion,
how
to
probe
and
record
open
end
responses,
establishing
rapport,
appropriate
pacing
and
delivery
and
CATI
system
instruction.
Prior
to
the
start
of
the
field
period,
interviewers
participate
in
a
project
briefing
to
provide
them
with
an
overview
of
the
study,
a
question
by
question
review
of
the
instrument,
CATI
practice,
and
role
playing.
Field
testing.
The
survey
will
be
administered
from
the
contractor's
Survey
Research
Center.
An
experienced
manager
of
telephone
interview
surveys
will
be
on­
site,
handling
survey
tasks
from
the
initial
establishment
of
a
field
organization
to
the
monitoring
of
survey
response.
Careful
quality
control
over
all
aspects
of
data
collection
and
preparation
is
an
integral
part
of
these
activities.

Telephone
surveys
for
community
participants
will
be
conducted
by
the
participating
states.
At
this
time,
the
pilot
states
also
plan
to
contract
with
a
survey
research
firm
to
administer
the
survey.
States
will
also
be
responsible
for
entering
and
coding
the
data.

4(
b)
Survey
Response
and
Follow­
up
The
target
response
rate
is
90%
for
printers.
Interview
survey
data
will
be
recorded
using
Computer
Assisted
Telephone
Interviewing
(
CATI)
by
experienced
interviewers.
Responses
are
entered
into
the
computer
by
the
interviewer
during
the
interview
to
minimize
data
processing
Page
18
time
and
data
entry
errors.
To
maximize
response,
several
methods
will
be
employed.
First,
interviewers
are
trained
in
identifying
and
contacting
the
most
appropriate
respondent.
In
the
case
of
printers,
this
includes
techniques
to
find
the
replacement
contact
when
the
original
contact
is
no
longer
with
the
company.
The
survey
is
designed
to
be
brief
(
approximately
12
minutes)
to
reduce
burden
and
improve
response
rates.
PrintSTEP
printers
will
know
about
the
survey
before
they
even
volunteer
for
the
PrintSTEP
program
and
their
trade
associations
will
be
sending
advance
letters
stressing
the
survey
is
brief
and
is
important
to
the
success
of
the
pilot
project
as
a
whole.
Additionally,
after
several
attempts
are
made
to
contact
the
respondent,
the
interviewer
will
leave
a
message
with
a
toll­
free
number
asking
the
respondent
to
return
the
call.

The
target
response
rate
for
community
members
is
75%.
The
interview
will
be
conducted
by
the
pilot
states
shortly
after
the
contact
participates
in
the
PrintSTEP
public
involvement
process
to
maximize
response
rates.

5.
ANALYZING
AND
REPORTING
SURVEY
RESULTS
5(
a)
Data
Preparation
As
described
above,
the
printers'
survey
will
be
conducted
using
Computer
Assisted
Telephone
Interviewing
(
CATI)
by
experienced
interviewers.
Responses
are
entered
into
the
computer
by
the
interviewer
during
the
interview
to
minimize
data
processing
time
and
data
entry
errors.
Data
from
the
fax­
back
forms
will
be
entered
by
contractor
staff.
The
contractor
maintains
an
in­
house
staff
of
trained
and
experienced
coders
who
have
worked
on
many
kinds
of
surveys
to
assure
data
preparation
of
the
highest
quality.
100%
key
verification
is
carried
out
to
ensure
accurate
data
entry.
Each
pilot
state
is
responsible
for
entering
the
information
from
the
printers'
applications
(
for
PrintSTEP
printers)
or
the
equivalent
form
(
for
the
comparison
group).

5(
b)
Analysis
An
analysis
of
the
survey
results
will
be
included
in
the
final
report
evaluation
addressing
what
changes
have
taken
place
in
the
PrintSTEP
facilities,
and
whether
or
not
those
changes
can
be
attributed
to
PrintSTEP.
All
information
will
be
presented
as
aggregate
results
and
the
facility
names
of
respondents
will
not
be
identified.
Quantitative
and
qualitative
results
will
be
tabulated.
Sample
table
shells
of
the
tabular
information
to
be
included
in
this
report
are
attached
in
Appendix
G.

The
contractor's
analysts
and
statisticians
reviewing
the
survey
results
will
prepare
summary
statistics
for
each
question,
and
will
conduct
a
thorough
analysis
of
the
data
with
respect
to
the
questions
posed
in
the
survey
objectives.
Trends
in
the
data
will
be
identified
using
a
statistical
analysis
program
(
SAS)
to
run
a
wide
range
of
analyses
including,
but
not
limited
to,
correlation
matrices.
Analyses
will
be
performed
to
examine
how
the
survey
objectives
(
e.
g.,
changes
environmental
releases/
wastes,
changes
in
pollution
prevention
practices)
are
influenced
by
the
pilot
state,
facility
size,
or
type
of
printing
process.
Additional
analyses
will
examine
relationships
among
the
objectives,
such
as
the
influence
of
public
involvement
on
reductions
in
environmental
releases/
wastes.
Page
19
5(
c)
Reporting
Results
The
final
report
will
be
posted
on­
line
and
will
also
be
available
in
hard
copy.
