Page
1
Information
Collection
Request
1941.03
for
the
Evaluation
of
PrintSTEP
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.

Current
Status
of
Pilot
Programs:

The
two
active
pilot
states
are
Missouri
and
New
Hampshire,
which
entered
into
EPA
cooperative
agreements
to
test
the
PrintSTEP
concepts
in
a
pilot
project.
Missouri's
pilot
is
focused
in
St.
Louis,
MO,
while
New
Hampshire's
pilot
is
state­
wide.
With
regard
to
affected
entities,
a
total
of
56
printing
facilities
are
participating
in
the
PrintSTEP
pilot
in
these
two
states.
In
order
to
join
the
pilot,
in
the
past,
these
printers
prepared
and
submitted
to
their
state
agency
a
single
PrintSTEP
application
(
covering
their
waste
water,
storm
water,
hazardous
waste
and
air
emissions).
All
PrintSTEP
applications
were
made
available
for
public
review,
and
for
several
applications,
community
members
were
given
an
opportunity
to
provide
comments.

Both
states
have
already
documented
successes
at
the
start
of
implementation
of
their
PrintSTEP
pilots.
In
New
Hampshire,
47
printers
are
participating
in
the
state­
wide
pilot.
All
but
one
of
these
printers
were
out
of
compliance
when
first
contacted
by
the
DES.
However,
as
a
result
of
joining
PrintSTEP,
all
of
the
participants
are
now
in
compliance
with
regard
to
their
wastewater,
stormwater,
hazardous
waste
and
emissions
requirements.
Page
2
New
Hampshire
sees
the
following
accomplishments
as
"
early
successes"
of
their
PrintSTEP
pilot:
1)
Achieved
20%
participation
of
the
printing
sector
statewide;
2)
Brought
small
businesses
into
compliance
not
otherwise
in
compliance;
3)
Promoted
environmental
awareness
within
this
sector;
4)
Established
communication
base
with
every
printer
in
New
Hampshire;
5)
Gave
the
printers
a
condensed
version
of
applicable
regulations
in
the
PrintSTEP
"
plain
language
workbook";
6)
Provided
operational
flexibility;
and
7)
Implemented
NH's
first
self­
certification
program.

Missouri
achieved
similar
successes
early
on
in
the
implementation
of
their
pilot
which
is
occurring
in
St.
Louis,
MO.
During
the
initial
application
process,
the
MO
PrintSTEP
Coordinator
toured
the
9
participating
printing
facilities
to
review
and
advise
printers
on
their
permitting,
air
quality,
hazardous
waste
review,
solid
waste
recycling,
wastewater
and
stormwater
procedures.
The
MO
DNR
has
already
documented
eight
examples
which
demonstrate
how
the
multi­
media
regulatory
approach
can
save
printers
and
regulatory
agencies
time
and
money,
as
well
as
improve
environmental
quality.

Current
Status
of
PrintSTEP
Evaluation:

As
a
pilot
project,
EPA
must
conduct
a
thorough
evaluation
to
determine
the
results
of
the
pilots
following
full
implementation
and
to
share
lessons
learned
with
other
states
which
may
want
to
implement
PrintSTEP­
like
programs.
Under
the
cooperative
agreements
with
EPA,
the
pilots
are
supposed
to
take
place
over
a
two­
year
period.
This
is
a
change
from
the
status
of
the
program
when
EPA
submitted
the
original
ICR
proposal;
at
that
time,
EPA
expected
the
PrintSTEP
pilots
to
last
3
years.
(
Nonetheless,
as
discussed
below,
the
basic
components
of
the
evaluation
have
remained
the
same,
namely,
there's
a
baseline
survey,
mid­
point
review
and
end­
of­
pilot
survey.)
The
evaluation
of
the
PrintSTEP
pilot
program
aims
to
systematically
identify
the
impacts
the
program
has
had
on
three
types
of
stakeholders:
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
encompasses
a
baseline
survey,
a
mid­
point
review
and
an
end­
of­
pilot
(
or
postpilot
survey
to
be
administered
by
an
EPA
contractor,
along
with
a
community
survey
and
interviews
with
the
PrintSTEP
coordinators
in
MO
and
NH.
The
baseline
survey
and
mid­
point
review
were
addressed
in
the
existing
ICR
and
will
have
already
been
completed
by
the
time
the
existing
ICR
expires
on
October
31,
2004.
(
The
draft
and
incomplete
baseline
assessment
is
included
in
appendix
1;
there
is
still
additional
data
which
must
be
added
to
the
baseline
and
that
will
be
completed
under
the
existing
ICR.
The
mid­
point
review
is
going
to
be
completed
shortly
before
the
expiration
of
the
existing
ICR.)
In
addition,
the
state
grantees
have
already
completed
the
survey
of
community
members
(
also
addressed
under
the
existing
ICR).
The
experiences
of
the
pilot
states
will
be
evaluated
through
in­
depth
interviews
with
the
PrintSTEP
coordinators
in
NH
and
MO;
this
latter
information
collection
is
not
included
in
the
ICR
as
fewer
than
10
Page
3
interviews
will
be
conducted
in
both
states.

For
that
reason,
this
request
for
OMB
approval
only
focuses
on
the
end­
of­
pilot
(
or
post­
pilot)
survey,
which
will
need
to
be
completed
in
final
form
at
the
conclusion
of
both
pilots.
This
is
the
only
remaining
part
of
the
evaluation
subject
to
this
information
collection
request.
(
The
end­
ofpilot
survey
could
not
be
conducted
under
the
existing
ICR
because
there
was
an
unexpected
delay
in
the
start­
up
of
the
state
pilots.)
Both
pilots
are
expected
to
conclude
by
November
2005,
with
the
end­
of­
pilot
survey
and
final
evaluation
being
completed
by
approximately
April,
2006.

The
results
of
the
evaluation
will
be
used
by
EPA
and
states
interesting
in
implementing
PrintSTEP­
like
programs
in
their
states;
there
will
be
a
"
lessons
learned"
section
of
the
evaluation
report
which
will
have
applicability
to
any
future
pilot
programs
which
EPA
or
the
states
decide
to
pursue.
Additionally,
the
multi­
stakeholder
representatives
(
and
their
constituents)
who
contributed
their
time
and
expertise
over
the
development
of
PrintSTEP
will
also
use
the
evaluation
results
to
assess
their
interest
in
participating
in
programs
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."

2(
b)
Practical
Utility/
Users
of
the
Data
It
is
expected
that
the
evaluation
results
and
lessons
learned
will
be
used
by
EPA
to
prepare
a
guide
for
developing,
implementing
and
evaluating
pilot
programs.
Also,
the
results
and
lessons
learned
will
be
shared
with
other
states
interested
in
establishing
PrintSTEP­
like
programs
in
their
states.
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
Page
4
results
will
be
tabulated
for
the
baseline,
midpoint
and
end
of
the
program,
and
the
following
research
questions
will
be
addressed
in
the
final
report:
°
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."

3.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
3(
a)
Non­
duplication
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
May
13,
2004,
FR
Volume
69,
Number
93,
page
26599.
No
comments
were
received
before
the
comment
period
ended
on
July
12,
2004.

3(
c)
Consultations
The
research
design,
data
collection
instruments
and
data
collection
plan
were
developed
by
Abt
Associates
Inc.,
under
U.
S.
EPA
contracts
68­
W6­
0021
and
68­
W­
99­
039.
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
Page
5
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,
non­
repetitive,
and
properly
sequenced,
skip
patterns
are
clear,
and
answer
categories
are
mutually
exclusive
and
collectively
exhaustive.

In
addition
to
the
above,
with
regard
to
this
request
for
an
extension,
EPA
consulted
with
members
of
the
public
and
affected
parties,
including
the
following
individuals:


Gary
Jones
Graphic
Arts
Technical
Foundation
(
GATF)
200
Deer
Run
Road
Sewickley,
PA
15143
412­
741­
6860,
Ext
608
Fax
­
412­
741­
2311

Tara
Olson
Technical
Specialist
NH
DES
­
Small
Business
Technical
Assistance
Program
360
Corporate
Drive
Portsmouth,
NH
03801
603­
436­
1139
tolson@
des.
state.
nh.
us

Bill
Hernlund
MO
Department
of
Natural
Resources
314­
416­
2960
They
acknowledged
that
the
extent,
size
and
complexity
of
each
individual
printers'
business
and
environmental
emissions
would
affect
the
amount
of
time
it
would
take
for
a
printer
to
complete
a
survey,
so
that
the
amount
of
time
to
complete
a
survey
might
vary
for
each
individual
printer
involved
in
the
PrintSTEP
program.
They
supported
the
suggested
and
average
costs
and
burdens
outlined
in
this
document.

3(
d)
Effects
of
Less
Frequent
Collection
Under
the
existing
ICR,
survey
data
has
already
been
collected
as
part
of
the
baseline
survey
from
the
majority
of
the
56
participating
printers
in
NH
and
MO.
In
addition,
under
the
existing
ICR
and
before
the
time
it
expires,
mid­
point
data
will
have
been
collected
from
the
56
participating
printers.
Under
the
existing
ICR,
data
has
also
been
collected
by
the
state
grantees
from
some
of
the
stakeholders/
community
members.
As
a
result,
this
information
collection
request
is
necessary
only
for
purposes
of
completing
the
end­
of­
pilot
survey
of
the
56
participating
printers.
The
data
for
the
end­
of­
pilot
survey
will
be
collected
once
and
cannot
be
collected
less
than
this.
Page
6
Eliminating
the
end­
of­
pilot
survey
would
jeopardize
the
entire
evaluation
because
we
would
not
have
final
results
data.

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
as
part
of
the
end­
of­
pilot
survey,
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
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
the
56
printing
facilities
Page
7
participating
in
the
PrintSTEP
pilot.

Parts
of
NAICS
323:
Printing
and
Related
Support
Activites
will
be
affected
by
this
evaluation.
In
terms
of
SIC
codes,
affected
facilities
may
include:
°
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
Information
already
collected
under
existing
ICR:

The
PrintSTEP
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,
community
members,
and
state
environmental
agencies.
Additionally,
environmental
justice
representatives
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.

As
stated
previously,
the
following
components
of
the
evaluation
were
completed
or
will
be
completed
under
the
existing
ICR:

1)
Baseline
survey
(
to
be
completed
under
existing
ICR):
Via
a
phone
survey,
most
of
the
printers
participating
in
the
pilot
responded
to
questions
regarding
their
pre­
PrintSTEP
requirements,
their
understanding
of
regulations,
and
their
motivation
to
join
PrintSTEP.
In
addition,
written
information
was
supplied
by
participating
printers.
The
pilot
states
collected
information
on
the
printers'
environmental
releases
and
wastes
from
PrintSTEP
applications
that
printers
submitted
when
joining
PrintSTEP.
(
This
will
be
used
for
comparison
purposes
with
the
environmental
release
data
to
be
obtained
from
printers
as
part
of
the
end­
of­
pilot
survey.
Printers
provide
annual
updates
of
this
information
to
the
state.)
The
application
includes
quantitative
information
such
as
quantity
and
type
of
hazardous
waste
generated
annually,
pounds
or
gallons
of
VOC­
containing
and
HAP­
containing
materials
used
per
year,
and
pollution
prevention
practices
employed.
Also,
printers
recorded
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
cost­
effective
for
printers
than
the
traditional
regulatory
process,
additional
written
information
regarding
the
costs
of
participating
in
PrintSTEP
was
collected
as
a
fax­
back
form
following
the
telephone
interview.
Page
8
Originally,
a
control
group
was
going
to
be
used
as
part
of
the
evaluation.
However,
it
was
determined
that
printers
who
are
not
participating
in
PrintSTEP
had
no
incentive
to
participate
in
a
control
group.
As
a
result,
a
different
approach
was
used.
State
data
bases
comparing
air
and
hazardous
waste
data
for
non­
participating
printers
were
utilized
in
order
to
create
a
pool
of
data
for
comparison
purposes.

Finally,
representatives
of
the
state
agencies
participating
in
PrintSTEP
were
interviewed
in
order
to
discuss
how
they
interacted
with
and
regulated
printers
prior
to
the
implementation
of
the
pilot
in
the
state.
Fewer
than
10
representatives
were
interviewed
as
part
of
this.

2)
Mid­
point
review
(
to
be
completed
under
existing
ICR):
The
mid­
point
review
included
interviews
with
printers
on
their
experiences
to
date
in
the
PrintSTEP
pilot.
In
addition,
the
state
agencies
participating
in
the
pilots
interviewed
stakeholders
at
the
state
level
in
order
to
determine
their
perspectives
on
PrintSTEP.

Information
to
be
collected
which
is
the
focus
of
this
ICR
request:

This
ICR
request
focuses
on
the
end­
of­
pilot
survey,
which
encompasses:


Telephone
survey
of
56
PrintSTEP
printers:
All
printers
who
volunteer
to
participate
in
the
pilot
will
be
contacted
to
complete
a
telephone
survey
at
the
end
of
the
pilot
to
obtain
their
comments
on
the
pilot.
(
The
draft
telephone
survey
form
is
in
appendix
2;
insignificant
changes
to
format
may
be
incorporated;
any
such
changes
would
not
increase
the
amount
of
time
necessary
to
complete
the
survey.)


Written
information
from
56
PrintSTEP
printers:
Written
information
will
be
supplied
by
participating
printers.
The
pilot
states
collected
information
on
the
printers'
environmental
releases
and
wastes
from
PrintSTEP
applications
that
printers
submitted
when
joining
PrintSTEP.
(
This
will
be
used
for
comparison
purposes
with
the
environmental
release
data
to
be
obtained
from
printers
as
part
of
the
end­
of­
pilot
survey.)
Printers
will
provide
annual
updates
of
this
information
to
the
state.
The
application
includes
quantitative
information
such
as
quantity
and
type
of
hazardous
waste
generated
annually,
pounds
or
gallons
of
VOC­
containing
and
HAP­
containing
materials
used
per
year,
and
pollution
prevention
practices
employed.
Also,
printers
recorded
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
cost­
effective
for
printers
than
the
traditional
regulatory
process,
additional
written
information
regarding
the
costs
of
participating
in
PrintSTEP
will
be
collected
as
a
fax­
back
form
following
the
telephone
interview.
(
The
draft
fax­
back
form
for
the
end­
of­
pilot
survey
is
in
appendix
3.)


Discussions
with
the
2
PrintSTEP
coordinators
from
the
2
state
agencies
in
NH
and
MO
who
are
administering
the
current
PrintSTEP
pilots.
The
discussions
will
focus
Page
9
on
what
the
PrintSTEP
coordinators
thought
of
the
pilot
and
the
work
entailed
on
the
state
agency's
part
in
order
to
implement
the
pilot
in
their
state.

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
The
56
PrintSTEP
program
participants
are
volunteers.
They
were
identified
by
each
state
through
outreach
and
applied
to
and
were
accepted
into
the
pilot
program.
In
Missouri,
the
pilot
is
being
implemented
only
in
the
St.
Louis
area.
In
New
Hampshire,
the
pilot
is
state­
wide.

The
printers'
survey
will
be
conducted
using
a
programmer
survey
tool
where
responses
are
translated
directly
into
a
database.
This
technique
was
selected
as
the
most
cost­
effective
means
to
minimize
data
processing
time
and
data
entry
errors,
to
reduce
the
burden
on
the
respondents
by
reducing
the
need
for
follow­
up
calls.
A
review
of
the
survey
instruments
by
the
survey
research
contractor
to
EPA
indicates
that
the
printer's
survey
will
take
approximately
12
minutes.

Only
cost
information
will
be
collected
from
the
PrintSTEP
printers
by
the
fax­
back
form
(
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
and
fax­
back
information
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
on
costs
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).

5(
c)
Small
Entity
Flexibility
Respondents
in
the
proposed
data
collection
will
include
a
few
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
looking
at
comparable
data
from
non­
participating
printers,
is
critical
in
evaluating
Page
10
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
for
the
end­
of­
pilot
survey
will
begin
after
approval
of
the
ICR
and
after
the
conclusion
of
the
two­
year
pilot
program
(
most
likely
during
the
November
2005
through
April
2006
timeframe).

A
final
report
will
be
completed
within
approximately
three
months
of
completing
the
post­
pilot
data
collection.
This
report
will
include
an
analysis
of
the
results
from
the
information
collected
from
printers,
stakeholders,
and
the
pilot
states.

6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
6(
a)
Respondent
Burden
The
focus
of
this
ICR
is
on
the
end­
of­
pilot
survey,
the
final
component
of
the
PrintSTEP
evaluation.
The
other
two
components
of
the
PrintSTEP
evaluation
(
meaning
the
baseline
assessment
and
mid­
point
review)
are
being
completed
under
the
existing
ICR.
For
background
information
only,
the
respondent
burden
and
costs
for
the
baseline
and
mid­
point
review
are
provided
in
the
charts
in
this
ICR
even
though
they
are
not
subject
to
the
ICR.
Thus
far,
for
the
baseline
survey,
of
the
56
participating
printers,
48
(
or
86%)
completed
the
telephone
survey
and
28
(
or
50%)
completed
the
fax­
back
from.
However,
more
printers
from
NH
are
still
expected
to
complete
the
survey
and
fax­
back
form
so
these
numbers
are
likely
to
increase.
The
reason
for
this
ICR
proposal
is
the
end­
of­
pilot
survey.

The
56
participating
printers
are
expected
to
be
included
in
the
end­
of­
pilot
survey.
Under
this
ICR
proposal,
the
major
data
to
be
collected
as
part
of
the
end­
of­
pilot
survey
include
the
following:


Participating
printers'
environmental
performance
relative
to
the
baseline,
including
their
use
of
pollution
prevention
practices.
(
Data
will
be
collected
through:
1)
interviews
with
printers;
2)
PrintSTEP
progress
reports
submitted
to
the
state
agencies
at
the
end
of
the
pilot,
which
include
updated
application
information;
and
3)
state
database
data
on
nonparticipating
printers.)
Page
11

Printers'
satisfaction
with
PrintSTEP
and
suggestions
for
program
improvements.
(
Data
will
be
collected
through
interviews
with
printers.)


Costs
to
printers
as
a
result
of
participating
in
PrintSTEP
versus
a
traditional
regulatory
approach.
(
Data
will
be
collected
through
a
fax­
back
form
associated
with
end
of
pilot
interviews.)
The
telephone
portion
of
the
printer's
end­
of­
pilot
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
5.5
hours
for
printers
to
complete.
For
PrintSTEP
printers,
this
environmental
release
information
will
be
collected
by
the
states
through
the
PrintSTEP
annual
reports
(
or
updates
to
the
information
in
the
original
applications).
The
total
for
the
end­
of­
pilot
survey
is
319
hours.
The
estimates
of
respondent
burden
for
the
end­
of­
pilot
survey
are
shown
under
item
#
3
in
the
table
below.

It
should
be
noted
that
the
annual
burden
would
be
approximately
106
hours
for
participating
printers.

6(
a)
Total
Respondent
Burden
for
Participating
Printers
Respondent
Type
Estimated
number
of
respondents
Time
to
complete
state
background
questionnaire
Time
to
respond
to
telephone
survey
(
hrs)
Time
to
complete
written
response
(
hrs)
Total
respondent
burden
(
hrs)

1.
Baseline
survey
(
To
be
completed
under
existing
ICR
­
NOT
subject
to
ICR
proposal)

Printers
responding
to
state
mailing
700
0.2
na
na
140
PrintSTEP
printer
56
0.2
5.5
319
Comparison
printer
0
0.2
5.5
0
2.
Mid
point
review
(
To
be
completed
under
existing
ICR
­
NOT
subject
to
ICR
proposal)

PrintSTEP
printer
56
0.2
5.5
319
Comparison
printer
0
0.2
5.5
0
Community
member
0
0.25
0.00
0
3.
End­
of­
Pilot
survey
(
Focus
of
ICR
proposal)

PrintSTEP
printer
56
0.2
5.5
319
Comparison
printer
0
0.2
5.5
0
Total
for
all
3
surveys
1098
Total
for
ICR
proposal
for
participating
printers
319
The
annual
burden
for
the
participating
printers
would
be
approximately
106
hours.

Respondent
Burden
for
Participating
States:
In
addition
to
the
printers,
the
2
state
PrintSTEP
coordinators
from
the
NH
DES
and
MO
DNR
who
are
implementing
the
2
PrintSTEP
pilots
would
be
interviewed.
In
addition,
there
are
some
other
burdens
associated
with
the
end­
of­
pilot
data
collection;
the
state
PrintSTEP
coordinators
assist
the
participating
printers
in
their
states
by
answering
questions
and
providing
assistance
with
calculations
associated
with
any
changes
in
environmental
emissions.
The
summary
of
burden
per
state
is
outlined
below
and
then
a
total
is
Page
12
provided.

For
NH
DES
to
assist
with
the
annual
updates
from
the
printers,
the
estimated
time
is
2
hours
per
47
printers,
or
94
hours
total
to
assist
the
printers
with
their
annual
updates/
reports.
Then,
in
order
for
NH
DES
to
answer
the
end­
of­
pilot
survey
questions,
the
estimate
is
1
hour.
Finally,
in
order
to
search
the
state
data
bases
to
provide
data
on
non­
participating
printers
for
comparison
purposes,
the
estimate
is
8
hours,
making
the
total
for
NH
DES
approximately
103
hours.

For
the
MO
DNR,
the
amount
of
time
is
less
because
there
are
only
9
participating
printers
in
the
St.
Louis
pilot
(
versus
NH's
pilot
which
is
state­
wide).
For
MO,
it
will
take
approximately
4
hours
total
to
assist
with
the
annual
updates
from
the
printers.
Then,
in
order
for
MO
DNR
to
answer
the
end­
of­
pilot
survey
questions,
the
estimate
is
1
hour.
Finally,
in
order
to
search
the
state
data
bases
to
provide
data
on
non­
participating
printers
for
comparison
purposes,
the
estimate
is
4
hours,
making
the
total
for
MO
DNR
approximately
9
hours.
(
Again,
this
difference
is
based
on
the
fact
that
47
printers
are
participating
in
NH,
while
only
9
are
participating
in
MO.)

So,
the
state
total
burden
is
approximately
112
hours
and
the
annual
state
burden
is
approximately
37
hours.

Combined
Respondent
Burden
for
Participating
Printers
and
State
Agencies:

When
you
combine
the
burden
(
outlined
above)
for
participating
printers
and
state
agencies,
the
approximate
total
burden
is
431
hours
or
an
annual
burden
of
approximately
143
hours.
This
amounts
to
an
annual
burden
of
2.46
or
2.5
hours
per
respondent.

The
combined
annual
burden
of
all
respondent
categories
is
as
follows:

a.
Participating
printers
­
approximately
106
hours
annual
burden
b.
Participating
states
­
approximately
37
hours
annual
burden
c.
Combined
burden
of
all
respondent
categories
­
approx.
143
hours
annual
burden
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.
Under
the
proposed
ICR,
the
only
cost
to
the
respondents
resulting
from
the
end­
of­
pilot
survey
is
their
time,
as
shown
in
the
table
below
for
participating
printers
under
item
#
3
("
End­
of­
Pilot
survey").
The
estimated
cost
for
participating
printers
for
the
end­
of­
pilot
survey
is
5.7
hours
for
each
of
the
56
printers
at
a
cost
of
$
43.12
per
hour,
for
a
total
of
$
13,764
for
participating
printers
for
this
ICR
proposal.
(
The
annual
total
cost
is
$
4,588.)
For
the
2
participating
state
coordinators,
the
cost
is
approximately
$
25.00
per
hour
(
based
on
salary
rates
and
overhead
provided
under
cooperative
agreement
applications
to
EPA),
for
a
total
of
$
2,800
(
and
an
annual
cost
of
$
933).
When
you
combine
the
estimated
cost
for
both
the
printers
and
the
state
coordinators,
the
grand
total
is
$
16,564
(
or
$
5,521
Page
13
on
an
annual
basis).

The
chart
below
provides
more
detail
on
total
costs
to
participating
printers.

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

1.
Baseline
survey
(
To
be
completed
under
existing
ICR
­
NOT
subject
to
ICR
proposal)

Printers
responding
to
state
mailing
700
0.2
140
$
43.12
$
6,037
PrintSTEP
printer
56
5.7
319
$
43.12
$
13,764
Comparison
printer
0
5.7
0
$
43.12
$
0
2.
Mid
point
review
(
To
be
completed
under
existing
ICR
­
NOT
subject
to
ICR
proposal)

PrintSTEP
printer
56
5.7
319
$
43.12
$
13,764
Comparison
printer
0
5.7
0
$
43.12
$
0
Community
member
0
0.25
0
$
27.95
$
0
3.
End­
of­
Pilot
survey
(
Focus
of
ICR
request)

PrintSTEP
printer
56
5.7
319
$
43.12
$
13,764
Comparison
printer
0
5.7
0
$
43.12
$
0
Total
for
All
3
surveys
$
47,329
Total
for
ICR
proposal
for
participating
printers
$
13,764
1Compensation
data
is
from
the
U.
S.
Department
of
Labor's
Bureau
of
Labor
Statistics'
Employer
Costs
for
Employee
Compensation
Summary,
March
2004.
(
http://
stats.
bls.
gov/
news.
release/
ecec.
toc.
htm)
Printers'
compensation
from
Table
11.
Private
industry,
by
occupational
group
and
full­
time
and
part­
time
status,
compensation
for
Professional
and
Related.
Community
member
compensation
from
Table
1.
Civilian
workers,
by
major
occupational
and
industry
group,
compensation
for
All
Workers.
Compensation
includes
wages
and
salaries,
and
benefits
(
paid
leave,
supplemental
pay,
insurance,
retirement
and
savings,
and
legally
required
benefits).
An
additional
loading
factor
of
17%
of
wages
is
included
for
overhead.
This
overhead
rate
is
used
in
EPA
economic
analyses
for
two
major
rulemakings:
Wage
Rates
for
Economic
Analyses
of
the
Toxics
Release
Inventory
Program,
June
10,
2002,
and
the
Revised
Economic
Analysis
for
the
Amended
Inventory
Update
Rule:
Final
Report,
August
2002.
This
overhead
loading
is
based
on
the
following
study:
Heiden
Associates,
Final
Report:
A
Study
of
Industry
Compliance
Costs
Under
the
Final
Comprehensive
Assessment
Information
Rule,
Prepared
for
the
Chemical
Manufacturers
Association,
December
14,
1989.

The
annual
cost
for
the
time
of
participating
printers
would
be
approximately
$
4,588.

Comprehensive
Summary
of
Respondent
Burden
Hours
and
Costs
on
an
Annual
Basis
Page
14
Taking
into
account
the
previous
explanation
of
respondent
burden
hours
and
costs
on
an
annual
basis,
the
following
list
summarizes
the
total
for
both
hours
and
costs
on
an
annual
basis:

Total
number
of
annual
respondents:
58
(
including
56
printers
and
2
states)
Total
annual
respondent
burden:
Participating
printers:
106
hours
annual
burden
Participating
states:
37
hours
annual
burden
Total
combined:
143
hours
annual
burden
Total
annual
burden
per
respondent:
Approximately
2.5
hours
Total
annual
capital/
startup
cost:
$
0
Total
annual
coast
for
O
&
M:
$
0
Total
annual
respondent
cost
for
their
time:
Participating
printers:
$
4,588
Participating
states:
$
933
Total
cost:
$
5,521
annual
respondent
cost
for
their
time
6(
c)
Estimating
Agency
Burden
and
Cost
The
current
contracted
cost
to
the
federal
government
is
approximately
$
74,000
for
project
management
and
implementation
of
the
evaluation
(
e.
g.
phone
surveys,
preparation
of
data
files,
and
analysis
and
reporting
of
results).
So,
the
annual
contractor
cost
for
this
would
be
approximately
$
24,666.
(
The
pilot
states
are
responsible
for
sharing
the
annual
reports/
updates
to
the
original
applications
from
the
printers;
that
cost
is
reflected
in
the
previous
section
under
respondent
costs.)
The
annual
labor
costs
for
the
part­
time
EPA
employee
who
works
on
PrintSTEP
on
a
part­
time
basis
would
be
approximately
$
4,166.
So,
the
EPA
annual
labor
costs
would
be
($
24,666
plus
$
4,166
for)
a
total
of
approximately
$
28,832
6(
e)
Reasons
for
Change
in
Burden
The
control
group
was
eliminated
and
there
are
a
total
of
56
printers
who
are
participating
in
the
evaluation
in
a
total
of
two
states.

6(
f)
Burden
Statement
The
annual
public
reporting
and
record­
keeping
burden
for
this
collection
of
information
is
estimated
to
average
2.5
hours
per
response.
Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
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
Page
15
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.
OECA­
2004­
0027
which
is
available
for
public
viewing
at
the
Enforcement
and
Compliance
Docket
and
Information
Center
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,
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
Enforcement
and
Compliance
Docket
and
Information
Center
is
(
202)
566­
1752.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
Use
EDOCKET
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.
Once
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
20503,
Attention:
Desk
Office
for
EPA.
Please
include
the
EPA
Docket
ID
No.
OECA­
2004­
0027and
OMB
control
number
2020­
0023
in
any
correspondence.

PART
B
OF
THE
SUPPORTING
STATEMENT
1.
SURVEY
OBJECTIVES,
KEY
VARIABLES,
AND
OTHER
PRELIMINARIES
1(
a)
Survey
Objectives
Because
PrintSTEP
is
a
multifaceted
program,
it
has
a
variety
of
goals.
The
PrintSTEP
Project
Team
identified
seven
types
of
expected
outcomes,
each
of
which
has
several
components:


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
for
the
end­
of­
year
pilot
will
be
gathered
from
printer's
updates
to
program
applications/
annual
reports
and
telephone
interviews.
The
specific
data
collection
activities
are
described
below.

Printers:
Telephone
Survey
and
Updates
to
PrintSTEP
Applications/
Annual
Reports
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.
The
56
participating
printers
Page
16
will
be
interviewed
by
telephone
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
telephone
survey
will
be
combined
with
written
information
from
updates
to
the
PrintSTEP
application
to
collect
the
data
needed.
The
annual
updates
will
complement
the
telephone
interviews
by
providing
written
data
on
environmental
releases
before
and
after
pilot
implementation.
Information
on
costs
incurred
related
to
PrintSTEP
or
traditional
environmental
regulation
will
be
collected
via
a
fax­
back
form
that
will
be
sent
to
the
printer
at
the
completion
of
the
telephone
interview.
An
EPA
contractor
will
conduct
the
telephone
survey
of
participating
printers.
Any
updates
to
the
PrintSTEP
applications
will
be
collected
by
the
pilot
states
as
part
of
the
PrintSTEP
process.

1(
b)
Key
Variables
Key
variables,
described
in
the
PrintSTEP
Evaluation
Strategy
include:
the
ease
in
completing
the
PrintSTEP
application
(
already
covered
under
the
existing
ICR);
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
will
have
any
serious
problems
or
delays
answering
the
questions
in
the
telephone
survey
portion
of
the
data
collection
or
submitting
any
updates
to
the
original
application.

2.
SURVEY
DESIGN
2(
a)
Target
Population
and
Coverage
The
population
of
interest
for
this
evaluation
is
printers
participating
in
the
PrintSTEP
pilot
program.
Fifty­
six
printers
are
participating
in
the
program.
For
such
a
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.

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.

Steps
are
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
Page
17
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
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
a
previous
contract,
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.

3.
PRETESTS
AND
PILOT
TESTS
Under
the
existing
ICR,
the
printer's
survey
instrument
was
subject
to
a
pretest
at
the
contractor's
Survey
Research
Center.
The
pretest
was
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.

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
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.
Review
of
the
survey
instruments
by
a
survey
research
contractor
indicates
that
the
printer's
survey
will
take
approximately
12
minutes.

Only
cost
information
will
be
collected
from
the
PrintSTEP
printers
by
fax­
back
form
(
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
the
telephone
survey
will
be
done
by
the
survey
research
firm.
Page
18
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
was
previously
administered
from
the
contractor's
Survey
Research
Center.
An
experienced
manager
of
telephone
interview
surveys
was
and
will
be
onsite
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.

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
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
answer
questions
and
their
state
agency
or
trade
associations
will
likely
be
sending
advance
letters
stressing
the
survey
is
brief
and
is
important
to
the
success
of
the
pilot
project
as
a
whole
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
Page
19
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.

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.

5(
c)
Reporting
Results
The
final
report
will
likely
be
posted
on­
line
and
will
also
be
available
in
hard
copy.
