April
17,
2003
Supporting
Statement
for
a
Request
for
OMB
Review
under
the
Paperwork
Reduction
Act
1
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1(
a)
Title:
Reporting
and
Recordkeeping
Requirements
under
EPA's
Hospitals
for
a
Healthy
Environment
(
H2E)
Program
EPA
ICR
No.
2088.01;
OMB
Control
No.
2070­
TBD
1(
b)
Short
Characterization
The
Hospitals
for
a
Healthy
Environment
(
H2E)
Program
is
an
Environmental
Protection
Agency
(
EPA)
voluntary
program
that
helps
hospitals
enhance
work
place
safety,
reduce
waste
and
waste
disposal
costs,
and
become
better
environmental
stewards
and
neighbors.
The
Program
is
an
outcome
of
a
partnership
between
the
American
Hospital
Association
(
AHA)
and
EPA.
More
specifically,
the
Program
is
based
on
a
1998
memorandum
of
understanding
(
MOU)
(
Attachment
A)
signed
by
AHA
and
EPA
to
provide
health
care
professionals
the
tools
and
information
necessary
to
reduce
mercury
waste,
reduce
the
overall
volume
of
waste,
and
identify
pollution
prevention
opportunities.
Within
EPA,
the
Program
was
developed
and
is
managed
by
EPA's
Office
of
Pollution
Prevention
and
Toxics
(
OPPT),
Pollution
Prevention
Division.

Since
its
inception,
the
H2E
Program
has
received
high­
level
recognition
in
the
Administration
for
the
importance
of
the
work,
as
well
as
from
industry
for
its
vital
role
in
providing
important
technical
resources
to
the
health
care
sector.
H2E
was
the
recipient
of
a
Hammer
Award
in
1999,
and
has
received
several
EPA
awards
subsequently.
The
health
care
industry
has
shown
its
enthusiasm
through
the
numerous
letters
of
support
(
Attachment
B),
as
well
as
through
the
level
of
participation
in
H2E
to
date.

Health
care
institutions
stand
to
gain
a
great
deal
through
participation
in
the
H2E
Program,
including:

­
useful
technical
information
that
will
assist
them
in
reducing
cost
of
waste
disposal;
­
reducing
waste
burden;
and
­
gaining
public
recognition.

The
ICR
is
an
important
component
of
this
program,
and
a
timely
review
of
this
application
will
help
ensure
the
H2E
Program's
sustained
success.

The
H2E
Program
is
divided
into
two
sub­
programs,
the
Partners
for
Change
Program
and
the
Champions
for
Change
Program.
The
Partners
for
Change
Program
recognizes
health
care
facilities
that
pledge
support
to
the
H2E
mission
and
develop
goals
for
reducing
waste
and
mercury
in
their
own
facilities.
The
Champions
for
Change
Program
recognizes
organizations
that
encourage
and
aid
health
care
facilities
to
participate
as
H2E
Partners,
provide
on­
going
promotional
or
technical
assistance
information,
or
make
changes
that
support
the
goals
of
the
H2E
Program
in
their
own
institutions.
An
organization's
decision
to
participate
in
the
H2E
Program
is
completely
voluntary.
Participation
begins
with
the
completion
of
and
submittal
to
Page
2
EPA
of
either
a
Partner
Registration
and
Pledge
Form
or
a
Champion
for
Change
Application
form
that
provides
EPA
with
general
organizational
information
[
see
Attachment
D
and
Attachment
F,
respectively].
A
senior
administrator
or
official
that
has
authority
to
commit
his/
her
organization
to
the
Program
signs
the
forms.
Once
an
organization
joins
the
Partners
for
Change
Program,
it
completes
and
submits
to
EPA
an
Annual
Facility
Assessment
Summary
and
Goals
Form
[
see
Attachment
E].
Organizations
have
broad
flexibility
in
designing
their
facility
environmental
goals.
Partners
and
Champions
may
also
apply
for
various
H2E
awards
by
submitting
an
Awards
Application
Form
[
see
Attachment
G].

EPA
expects
new
Partners
to
spend
time
up­
front
in
establishing
a
solid
foundation
for
H2E
initiatives
by
documenting
their
environmental
baseline
when
they
first
join
H2E
and
by
setting
their
own
facility
performance
goals,
and
allots
six
months
for
Partners
to
establish
their
goals.
During
the
first
year
and
in
all
subsequent
years,
a
Partner
will
submit
the
Annual
Facility
Assessment
Summary
and
Goals
Form.
This
form
is
designed
to
help
a
facility
establish
its
own
environmental
baseline,
continue
to
track
its
own
environmental
progress,
provide
basic
contact
and
facility
information,
waste
and
mercury
assessment
summaries,
environmental
policy
information,
and
a
description
of
its
pollution
prevention
(
P2)/
waste
reduction
goals
and
activities.
EPA
expects
organizations
to
implement
their
H2E
programs
and
report
on
their
progress
by
January
31
of
each
subsequent
year
after
joining,
unless
less
than
nine
months
have
passed
since
the
initial
submittal.
The
Annual
Facility
Assessment
Summary
and
Goals
Form
is
the
main
way
Partners
for
Change
report
their
environmental
progress
to
EPA.

EPA
collects
the
information
in
hard
copy
form
or
through
an
online
registration
and
reporting
system
and
then
enters
and
stores
it
in
a
database.
The
information
collection
under
the
H2E
Program
is
necessary
to
allow
EPA
to:

°
Gauge
progress
of
individual
facilities
participating
in
the
Program,
as
well
as
the
overall
success
of
the
Program;
°
Recognize
Partner
accomplishments;
°
Identify
effective
P2/
waste
reduction
strategies
to
share
with
others;
°
Identify
areas
where
additional
technical
assistance
or
information
would
be
useful
for
individual
Partners
or
more
generally
for
Program
participants;
°
Measure
environmental
outcomes
of
actions
taken
by
facilities;
°
Recognize
participants
with
significant
P2/
waste
reduction
accomplishments
at
annual
national
recognition
ceremonies;
°
Aggregate
and
analyze
the
data
in
order
to
monitor
progress
towards
meeting
of
the
EPA/
AHA
agreement;
and
°
Evaluate
opportunities
for
improving
the
H2E
Program.

Recognizing
Partner
achievements
is
important
to
help
EPA
spur
other
Partners
on
to
reduce
more
waste.
Sharing
effective
P2/
waste
reduction
strategies
with
others
is
a
fundamental
objective
of
the
H2E
Program.

The
H2E
Partners
for
Change
Program
currently
has
273
Partners.
EPA
expects
Program
membership
to
increase
by
500
Partners
for
each
year
of
this
ICR.
During
the
first
year
of
participation
in
the
Program,
the
information
collection
activities
will
cost
each
Partner
approximately
$
918
if
they
choose
to
submit
an
award
application,
and
$
238
if
they
do
not.
For
each
subsequent
year,
the
information
collection
activities
will
cost
each
Partner
approximately
Page
3
$
740
if
they
choose
to
submit
an
award
application,
and
$
60
if
they
do
not.
The
Agency
does,
however,
expect
many
organizations
to
recognize
substantial
cost
savings
through
the
implementation
of
their
P2/
waste
reduction
initiatives.

The
H2E
Champions
for
Change
Program
currently
has
30
Champions.
EPA
expects
Program
membership
to
increase
by
50
Champions
during
each
year
of
this
ICR.
During
the
first
year
of
participation
in
the
Program,
the
information
collection
activities
will
cost
each
Champion
approximately
$
772
if
they
choose
to
submit
an
award
application,
and
$
92
if
they
do
not.
For
each
subsequent
year,
the
information
collection
activities
will
cost
each
Champion
approximately
$
698
if
they
choose
to
submit
an
award
application,
and
$
18
if
they
do
not.

2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
2(
a)
Need/
Authority
for
the
Collection
Section
6604(
b)(
5)
of
the
Pollution
Prevention
Act
(
PPA),
42
U.
S.
C.
13103(
b)(
5)
[
see
Attachment
C],
directs
EPA
to
facilitate
the
adoption
of
source
reduction
techniques
by
businesses,
including
the
distribution
of
source
reduction
information
to
businesses.
On
June
24,
1998,
the
American
Hospital
Association
(
AHA)
and
EPA
signed
a
landmark
memorandum
of
understanding
(
MOU)
identifying
goals
to
reduce
the
impact
of
health
care
facilities
on
the
environment
[
see
Attachment
A].
The
Parties
to
the
MOU
affirmed
the
Congressional
goals
and
principles
set
forth
in
the
PPA,
42
U.
S.
C.
13101
through
13109,
particularly
the
goal
of
reducing
the
generation
of
pollution
at
its
source,
preferentially
to
the
recycling,
treatment,
and/
or
disposal
of
such
waste.
More
specifically,
the
MOU
identifies
goals
of
the
virtual
elimination
of
mercury;
reduction
of
persistent,
bioaccumulative,
and
toxic
(
PBT)
chemicals;
and
a
thirty­
three
percent
reduction
of
total
waste
in
all
hospitals
by
2005
and
a
fifty
percent
reduction
by
2010.

In
conjunction
with
the
American
Nurses
Association
and
Healthcare
Without
Harm,
AHA
and
EPA
implemented
the
MOU
by
developing
the
H2E
Partners
for
Change
and
Champions
for
Change
Programs.
The
H2E
Programs'
information
collection
activities
will
assist
the
Agency
in
meeting
the
goals
of
the
PPA
and
the
MOU
by
facilitating
the
education
of
health
care
professionals
about
P2/
waste
reduction
opportunities
and
the
distribution
of
necessary
source
reduction
tools
and
information.
More
specifically,
EPA
needs
to
collect
initial
information
in
the
Partner
Registration
and
Pledge
Form
to
formally
establish
participation
in
the
H2E
Partners
for
Change
Program,
obtain
general
information
on
new
H2E
Partners,
and
obtain
a
pledge
of
commitment
to
H2E's
goals.
EPA
needs
to
collect
the
information
in
the
Annual
Facility
Assessment
Summary
and
Goals
Form
in
order
to
establish
an
environmental
baseline
for
each
facility,
measure
each
participant's
efforts
and
progress
over
time,
gauge
overall
Program
progress
in
preventing
pollution
and
reducing
waste,
and
identify
effective
P2/
waste
reduction
strategies
for
other
participants
in
the
Program.

For
the
H2E
Champions
for
Change
Program,
EPA
needs
to
collect
initial
information
in
the
Champion
for
Change
Application
form
to
establish
participation
in
the
Champion
Program,
obtain
general
contact
information,
and
identify
the
activities
each
Champion
will
conduct
to
achieve
the
Program's
goals.

Both
Partners
and
Champions
may
apply
for
various
annual
or
one­
time
H2E
awards.
In
Page
4
order
to
evaluate
the
award
candidates,
EPA
needs
to
collect
information
in
the
Awards
Application
Form
about
specific
activities
related
to
the
award
category.

2(
b)
Practical
Utility/
Users
of
the
Data
The
information
collected
by
the
H2E
Program
is
not
designed
or
intended
to
support
regulatory
decision­
making
by
EPA.
EPA
uses
the
information
collected
in
the
Partner
Registration
and
Pledge
Form
to:
(
1)
update
its
database
containing
information
on
H2E
participants;
(
2)
initiate
contact
with
the
primary
person
in
charge
of
the
Partner's
H2E
initiatives;
and
(
3)
prepare
a
list
of
H2E
Partners.
The
information
in
the
database
is
used
to
track
organization
status
and
prepare
reports
and
mailing
lists.

EPA
uses
the
information
collected
in
the
Annual
Facility
Assessment
Summary
and
Goals
Form
to:
(
1)
establish
an
environmental
baseline
for
each
Partner;
(
2)
record
the
Partner's
activities
and
progress
in
the
database;
(
3)
identify
effective
P2
practices
to
develop
and
disseminate
as
case
studies
and
other
materials
or
recommend
to
Partners
seeking
effective
P2
goals;
(
4)
identify
areas
where
additional
technical
assistance
or
information
would
be
useful
for
individual
Partners
or
more
generally
for
Program
participants,
e.
g.,
low
mercury
elimination
figures
may
indicate
a
need
for
increased
education
about
alternatives
to
mercury­
containing
devices;
(
5)
recognize
participants
with
significant
P2
accomplishments
at
annual
national
recognition
ceremonies;
(
6)
aggregate
and
analyze
the
data
in
order
to
prepare
and
measure
progress
toward
the
goals
of
the
MOU;
and
(
7)
evaluate
opportunities
for
improving
the
H2E
Program.

EPA
uses
the
general
information
collected
in
the
Champion
for
Change
Application
form
to:
(
1)
update
its
database
containing
information
on
H2E
participants;
(
2)
initiate
contact
with
the
primary
person
in
charge
of
the
Champion's
H2E
initiatives;
and
(
3)
prepare
a
list
of
H2E
Champions.
The
information
in
the
database
is
used
to
track
organization
status
and
prepare
reports
and
mailing
lists.
EPA
uses
the
information
on
the
activities
Champions
are
conducting
to
(
1)
record
the
Champion's
activities
in
the
database;
and
(
2)
identify
areas
where
additional
technical
assistance
or
information
would
be
useful
for
individual
Champions
or
more
generally
for
Program
participants.

EPA
uses
the
information
collected
in
the
Awards
Application
Form
to
evaluate
the
achievements
award
candidates
have
made
in
specific
areas.

3.
NON­
DUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
3(
a)
Non­
Duplication
EPA
is
ensuring
that
respondents
are
not
requested
to
provide
information
that
has
been
collected
by
EPA
or
any
other
Federal
agency.
Several
health
care­
related
organizations
are
members
of
EPA's
WasteWise
Program,
which
collects
waste
reduction
data
from
all
types
of
businesses
and
organizations,
and
EPA's
Energy
Star
®
energy
efficiency
program.
EPA
coordinates
H2E
with
these
programs
to
ensure
non­
duplication
of
information
collection.
Page
5
Some
states
and
regions
have
implemented
programs
that
address
P2
activities
at
hospitals
and
health
care
facilities
or
allow
for
the
collection
of
P2
information
as
part
of
a
broader
collection
of
environmental
performance
information.
In
some
cases,
these
programs
were
incorporated
into,
or
are
based
on
and
directly
linked
to
the
H2E
Program.
For
example,
Ohio
EPA
signed
the
Ohio
Healthy
Hospitals
Pollution
Prevention
Initiative
with
the
Ohio
Hospital
Association,
based
on
the
federal
MOU
signed
by
EPA
and
AHA.
Other
examples
include
the
EPA
Region
1
Mercury
Challenge
and
Health
Care
Without
Harm/
National
Wildlife
Federation's
Making
Medicine
Mercury
Free
Program.
In
these
cases,
the
programs
are
either
incorporated
within
or
fully
coordinated
with
the
national
H2E
Program
to
ensure
non­
duplication
of
information
collection.
A
few
other
state
programs
have
been
implemented
and
continue
to
be
administered
separately
from
H2E.
One
example
is
the
Sustainable
Hospitals
Project
(
SHP),
which
is
a
partnership
program
that
includes
Massachusetts
state
agencies.
EPA
is
identifying
and
working
with
these
programs
to
ensure
non­
duplication
of
information
collection.

Where
appropriate,
EPA
will
accept
other
programs'
reporting
forms
in
lieu
of
the
H2E
Annual
Facility
Assessment
Summary
and
Goals
Form.

3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
In
proposing
to
renew
this
ICR,
EPA
provided
a
60­
day
public
notice
and
comment
period
that
ended
on
October
18,
2002
(
67
FR
53789,
August
19,
2002).
EPA
received
comments
from
the
New
Hampshire
Hospital
Association;
Columbia
St.
Mary's
Hospital,
Milwaukee,
WI;
Mills
Peninsula
Health
Services,
San
Mateo,
CA;
Center
for
Environmental
Health,
Oakland,
CA;
the
City
of
Albuquerque
(
NM)/
Public
Works
Dept.;
the
American
Nurses
Association
and
Minnesota
Technical
Assistance
Program.
Since
all
of
the
comments
were
supportive,
EPA
did
not
modify
the
ICR
that
was
made
available
for
public
comment.
Copies
of
the
comments
are
included
as
Attachment
H.

3(
c)
Consultations
EPA
has
received
significant
feedback
on
the
H2E
Program
from
key
stakeholders.
In
completing
the
MOU
and
implementing
the
H2E
Program,
EPA
worked,
and
continues
to
work,
closely
with
AHA,
which
consists
primarily
of
health
care
provider
organizations
across
the
United
States.
The
H2E
Program
has
also
involved
the
efforts
of
representative
of
several
stakeholder
groups
including
the
American
Nurses
Association,
Health
Care
Without
Harm,
state
and
local
government
agencies,
state
and
metropolitan
health
care
associations,
health
care
environmental
services
professionals,
health
care
materials
managers,
physicians,
nurses,
waste
management
industry
representatives,
and
product
manufacturers.

The
H2E
effort
is
built
upon
the
collaborative
working
relationship
of
this
network
of
Partners
and
their
commitment
to
the
goals
of
mercury
elimination
and
waste
volume
and
toxicity
reduction
in
hospitals.
Prior
to
the
implementation
of
the
H2E
Partners
for
Change
and
Champions
for
Change
Programs,
efforts
focused
on
forming
the
Environmental
Leadership
Council
(
ELC),
which
consists
of
representatives
from
the
stakeholder
groups
listed
above
and
serves
as
the
oversight
body
for
the
project.
The
ELC
established
12
working
groups
to
develop
information
products
and
guide
the
development
of
the
H2E
Program.
ELC
representatives
and
other
stakeholders
provided
guidance
and
feedback
on
the
content
of
the
program
forms
and
the
corresponding
burden
hour
estimates.
ELC
members
and
other
stakeholders
generally
agreed
with
the
content
and
burden
hour
estimates
for
the
program
forms.
EPA
also
posted
draft
versions
of
Page
6
the
forms
on
the
H2E
Web
site
(
www.
h2e­
online.
org)
and
solicited
comments,
but
no
comments
were
received.

By
gaining
an
understanding
of
current
health
care
providers'
practices
and
barriers
to
environmental
programs,
EPA
was
able
to
structure
the
H2E
Program
to
best
suit
participant
needs
and
minimize
the
information
collection
burden.
EPA
also
worked
with
staff
from
other
EPA
voluntary
programs,
including
WasteWise
and
ENERGY
STAR
®
,
to
gain
insights
into
program
structure
and
simplified
reporting
requirements.

Specific
individuals
consulted
include:

Rebecca
Maron
312­
422­
3773
American
Hospital
Association
Laura
Brannen
603­
795­
4040
Healthcare
Without
Harm
Marian
Condon
202­
651­
7134
American
Nurses
Association
Lynn
Garske
818­
352­
3093
Kaiser
Permanente,
California
Pierre
Gonyon
734­
712­
3315
McPherson
Hospital,
Michigan
Dan
Stickles
616­
363­
0941
St.
Mary's
Mercy
Medical
Center,
Michigan
Elaine
Bauer
610­
355­
2025
Catholic
Health
East
Jean
Livingston
847­
704­
7463
Consortia
Catherine
Zimmer
612­
624­
4635
Minnesota
Technical
Assistance
Program
Attachment
B
includes
letters
of
support
from
stakeholders.
EPA
and
AHA
received
these
letters
in
2001
when
AHA
was
reassessing
its
role
in
the
Program.

In
addition,
during
the
period
of
public
comment
on
this
ICR,
the
following
individuals
commented
upon
the
ICR
in
a
supportive
way:

Barbara
Blakeney
202­
651­
7000
American
Nurses
Association
Debbie
Augustine
603­
225­
0900
New
Hampshire
Hospital
Association
Robert
H.
Hogrefe
505­
873­
7030
City
of
Albuquerque,
New
Mexico
Ellis
J.
Hooker
414­
291­
1768
Columbia
St.
Mary's
Hospital,
Wisconsin
Mamta
Khanna
510­
594­
9864
Center
for
Environmental
Health,
California
Gail
D.
Lee
650­
696­
5706
Mills
Peninsula
Health
Services,
California
Catherine
Zimmer
612­
624­
4635
Minnesota
Technical
Assistance
Program
3(
d)
Effects
of
Less
Frequent
Collection
The
Partner
Registration
and
Pledge
Form
and
Champion
for
Change
Application
form
are
one­
time
information
submissions
for
organizations
that
wish
to
participate
in
the
H2E
Partners
for
Change
or
Champions
for
Change
Programs,
and
therefore
could
not
be
conducted
less
frequently.
Partners
submit
the
Annual
Facility
Assessment
Summary
and
Goals
Form
on
an
annual
basis.
Requiring
this
report
on
a
less
frequent
basis
would
hinder
EPA
efforts
to
generate
relevant
and
timely
case
studies
and
success
stories
that
would
be
helpful
to
participants.
Partners
and
Champions
may
choose
to
apply
for
annual
and
one­
time
awards
by
submitting
the
Page
7
Awards
Application
Form.
Requiring
this
information
on
a
less
frequent
basis
would
hinder
EPA
efforts
to
recognize
outstanding
achievements
and
progress
in
the
annual
H2E
awards
ceremonies.
Less
requent
data
collection
would
hinder
EPA's
ability
to
gauge
progress
by
individual
organizations
and
the
Program
as
a
whole
and
to
gain
the
information
necessary
to
publicly
recognize
exemplary
Partner
waste
reduction
activities.
Most
importantly,
less
frequent
data
collection
would
severely
hinder
EPA's
ability
to
measure
the
Program's
success
as
it
relates
to
the
goals
outlined
in
the
MOU.

3(
e)
General
Guidelines
All
of
the
collection
activities
described
within
this
ICR
adhere
to
OMB's
General
Guidelines.

3(
f)
Confidentiality
No
information
collected
by
EPA
under
the
H2E
Program
comprises
confidential
business
information.

3(
g)
Sensitive
Questions
No
questions
of
a
sensitive
nature
are
asked
in
any
of
the
reporting
forms.

4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
4(
a)
Respondents
and
NAICS
Codes
The
H2E
Partners
for
Change
Program
targets
establishments
primarily
engaged
in
furnishing
medical,
surgical,
and
other
health
services
to
individuals.
Establishments
of
associations
or
groups,
such
as
Health
Maintenance
Organizations
(
HMOs),
primarily
engaged
in
providing
medical
or
other
health
services
to
members
are
targeted
as
Partners,
but
those
which
limit
their
services
to
the
provision
of
insurance
against
hospitalization
or
medical
costs
participate
as
Champions.
Individual
organizations
may
participate
in
the
Program
as
Partners
and
Champions.

While
EPA
focuses
its
H2E
Partner
marketing
efforts
on
hospitals
and
other
health
care
provider
organizations,
the
Program
is
open
to
all
companies,
organizations,
schools,
colleges,
universities,
and
federal,
state,
and
local
governments
that
are
able
to
implement
activities
that
support
the
Program's
goals.
The
following
is
a
list
of
North
American
Industry
Classification
System
(
NAICS)
codes
and
associated
industries
that
are
most
likely
to
be
affected
by
information
collection
requirements
covered
under
this
ICR:

NAICS
Codes
Affected
Industry
6211
Offices
of
Physicians
6212
Offices
of
Dentists
6213
Offices
of
Other
Health
Practitioners
6214
Outpatient
Care
Centers
6215
Medical
and
Diagnostic
Laboratories
Page
8
339116
Dental
Laboratories
6216
Home
Health
Care
Services
6219
Other
Ambulatory
Health
Care
Services
6221
General
Medical
and
Surgical
Hospitals
6222
Psychiatric
and
Substance
Abuse
Hospitals
6223
Specialty
(
except
Psychiatric
and
Substance
Abuse)
Hospitals
6231
Nursing
Care
Facilities
6232
Residential
Mental
Retardation,
Mental
Health,
and
Substance
Abuse
Facilities
6233
Community
Care
Facilities
for
the
Elderly
6239
Other
Residential
Care
Facilities
The
H2E
Champions
for
Change
Program
targets
a
range
of
health
care­
related
organizations
for
recruitment
as
Champions,
including
health
systems,
health
care­
related
professional
associations,
Group
Purchasing
Organizations
(
GPOs),
member­
based
organizations
that
champion
the
H2E
Partners
for
Change
Program
to
their
members
(
e.
g.,
environmental
groups,
grassroots
organizations),
vendors,
manufacturers,
consultants,
and
other
service
providers.
Although
these
organizations
can
fall
under
a
wide
range
of
industry
sectors,
most
will
come
from
the
codes
listed
above
for
Partners,
or
from
the
following
NAICS
codes:

NAICS
Codes
Associated
Industry
8132
Grantmaking
and
Giving
Services
8133
Social
Advocacy
Organizations
8134
Civic
and
Social
Organizations
8139
Business,
Professional,
Labor,
Political
and
Similar
Organizations
4(
b)
Information
Requested
Once
a
prospective
organization
reviews
the
H2E
Partners
For
Change
materials
and
decides
to
join
the
Program,
it
submits
a
Partner
Registration
and
Pledge
Form
(
Attachment
D).
By
January
31
of
each
year,
Partners
that
joined
the
Program
by
August
31
of
the
preceding
year
report
on
the
progress
made
toward
achieving
their
goals
on
the
Annual
Facility
Assessment
Summary
and
Goals
Form
(
Attachment
E).
Organizations
that
join
the
H2E
Champions
for
Change
Program
need
only
submit
the
Champion
for
Change
Application
form
(
Attachment
F)
at
the
time
they
join.
Partners
and
Champions
that
wish
to
apply
for
awards
are
required
to
submit
the
Awards
Application
Form
(
Attachment
G)
by
March
1.

All
of
the
forms
are
available
in
hard
copy
or
electronic
form.
Participants
can
use
the
hard
copy
forms
they
receive
from
EPA
by
mail
or
download
PDF
versions
of
the
forms
from
the
H2E
Web
site.
Participants
will
also
be
able
to
use
the
online
registration
and
reporting
system
(
planned
for
2004).

Partner
Registration
and
Pledge
Form
H2E
Partners
for
Change
Program
participants
complete
and
submit
to
EPA
a
standard,
onepage
Partner
Registration
and
Pledge
Form
that
provides
basic
organization
information.

(
i)
Data
items:
Page
9
The
reporting
items
include:

°
Facility
name
and
Web
site
URL;
°
Name,
title,
address,
phone
number,
fax
number,
and
e­
mail
address
of
the
Partner's
primary
contact
person;
°
Description
of
facility
and
any
relevant
affiliations;
°
Signature,
name,
and
title
of
senior
administrator
and
the
date
signed.

°
OPTIONAL:
The
Partner
may
provide
additional
information
describing
the
organization's
previous
waste
reduction
efforts
under
other
programs
and
previous
waste
assessment
efforts.

(
ii)
Respondent
activities:

Participants
conduct
the
following
activities
in
order
to
complete
and
submit
the
Partner
Registration
and
Pledge
Form:

°
Review
the
H2E
Partners
for
Change
Program
information
and
overall
H2E
Program
information;
°
Decide
whether
to
join
the
Program;
°
Select
a
primary
contact
person
for
the
Program;
°
Complete
the
Partner
Registration
and
Pledge
Form,
including
obtaining
the
signature
of
a
senior
administrator;
and
°
Fax
or
mail
the
form
to
EPA
or
submit
the
form
through
the
online
registration
system.

Annual
Facility
Assessment
Summary
and
Goals
Form
H2E
Partners
for
Change
participants
complete
and
submit
to
EPA
a
standard,
two­
page
Annual
Facility
Assessment
Summary
and
Goals
Form
that
describes
the
Partner's
P2/
waste
reduction
goals
and
progress.
This
form
is
due
within
six
months
of
joining
H2E
(
for
new
Partners)
and
by
January
31
of
each
subsequent
year,
unless
less
than
nine
months
have
passed
since
submittal
of
the
initial
form.

(
i)
Data
items:

The
reporting
items
include:

°
Section
1:
Contact
Information.

­­
Facility/
System
name;
­­
Name,
title,
address,
phone
number,
fax
number,
and
e­
mail
address
of
the
Partner's
primary
contact
person;
and
­­
Year
for
which
the
information
is
being
requested.

°
Section
2:
Facility
Information.
The
Partner
completes
the
following
data
items
depending
on
which
facility
type(
s)
are
applicable:
Page
10
­­
If
"
In­
Patient/
Hospital"
facility:
number
of
adjusted
patient
days,
number
of
beds,
and
number
of
staff;
­­
If
"
Ambulatory
Care/
Outpatient
Clinics"
facility:
number
of
outpatient
visits
and
number
of
staff;
­­
If
"
General
Administrative"
facility:
number
of
staff;
and
­­
If
"
Long
Term
Care"
facility:
number
of
beds
and
number
of
staff.

°
Section
3:
Facility
Waste
Assessment
Summary.

­­
Tons
of
solid
waste
generated
per
year,
amount
of
solid
waste
as
percent
of
total
waste,
and
annual
cost
of
solid
waste
management;
­­
Tons
of
waste
recycled/
reused
per
year,
amount
of
waste
recycled/
reused
as
percent
of
total
waste,
and
annual
cost
of
recycling/
reuse
activities;
­­
Tons
of
regulated
medical
waste
generated
per
year,
amount
of
regulated
medical
waste
as
percent
of
total
waste,
and
annual
cost
of
regulated
medical
waste
management;
­­
Tons
of
hazardous
waste
generated
per
year,
amount
of
hazardous
waste
as
percent
of
total
waste,
and
annual
cost
of
hazardous
waste
management;
and
­­
Total
tons
of
waste
per
year
from
all
categories
and
annual
cost
of
all
waste
management
activities.

°
Section
4:
Mercury
Assessment.
Partners
answer
"
yes"
or
"
no"
to
four
mercuryrelated
questions:

­­
"
Is
your
facility
virtually
mercury
free?"
­­
"
Has
your
facility
conducted
a
facility
inventory
of
mercury­
containing
devices
and
chemicals?"
­­
"
Has
your
facility
implemented
a
mercury
purchasing
policy?"
­­
"
Has
your
facility
eliminated
mercury­
containing
patient
care
devices?"
and
­­
OPTIONAL:
The
Partner
may
provide
a
description
of
mercury
elimination
efforts
to
date.

°
Section
5:
Environmental
Policies.
Partners
indicate
whether
or
not
they
have
implemented
each
of
the
following
by
checking
either
the
"
yes"
or
"
no"
box:
a
facility
environmental
commitment
statement,
a
comprehensive
waste
management
policy,
a
mercury
management/
elimination
policy,
and
an
environmentally
preferable
purchasing
policy.

°
Section
6:
H2E
Goals.
Partners
are
asked
to
list
their
H2E
goals
and
describe
source
reduction,
mercury
elimination,
recycling,
reuse,
and
donation
activities
they
will
implement
to
achieve
each
goal.

­­
The
H2E
goals
the
Partner
plans
to
undertake
and
the
source
reduction,
mercury
elimination,
recycling,
reuse,
and
donation
activities
the
Partner
will
implement
to
achieve
each
goal.

EPA
assumes
that
participating
organizations
keep
facility
information,
waste
assessment,
and
policy
data
as
a
Common
Business
Practice.
The
other
data
items
do
not
require
any
record­
Page
11
keeping
activities,
and
therefore,
burden
associated
with
recordkeeping
is
not
included
in
this
ICR.

(
ii)
Respondent
activities:

Participants
conduct
the
following
activities
in
order
to
complete
and
submit
the
Annual
Facility
Assessment
Summary
and
Goals
Form:

°
Review
the
information
contained
in
the
H2E
Self­
Assessment
Guide
(
available
on
the
H2E
Web
site),
which
describes
how
to
conduct
baseline
waste
assessments
and
identify
P2
opportunities;
°
Conduct
at
least
a
cursory
review
of
materials
used
or
disposed
of
by
the
organization
(
level
of
detail
and
effort
will
vary
among
organizations
and
may
include
establishing
a
P2/
waste
reduction
team)
to
determine
cost
effective
H2E
goals;
°
Set
up
a
measurement/
tracking
system
for
P2/
waste
reduction
activities,
if
such
a
system
is
not
already
established
(
level
of
detail
and
effort
will
vary
among
organizations);
°
Collect
and
review
records
to
assess
progress
during
the
reporting
year;
°
Complete
the
Annual
Facility
Assessment
Summary
and
Goals
Form;
°
Fax
or
mail
the
form
to
EPA
or
submit
the
form
through
the
online
reporting
system;
and
°
Respond
to
EPA
questions
to
clarify
data
and/
or
goals.

Champion
for
Change
Application
form
Champions
complete
and
submit
to
EPA
a
standard,
one­
page
Champion
for
Change
Application
form
that
provides
basic
association
information
and
describes
recruitment
and
promotional
activities.

(
i)
Data
items:

The
reporting
items
include:

°
Organization
name
and
Web
site
URL;
°
Name,
title,
address,
phone
number,
fax
number,
and
e­
mail
address
of
the
Champion's
principal
contact
person;
°
Approximate
number
of
health
care
facilities
associated
with
the
organization;
°
Type
of
organization;
°
Statement
of
current
compliance
with
pertinent
regulations;
°
Expression
of
commitment
to
waste
reduction
and
pollution
prevention
activities
°
Descriptions
of
objectives
and
implementation
strategies
to
effect
waste
reduction
and
pollution
prevention
efforts;
and
°
Signature,
name,
and
title
of
senior
official
and
the
date
signed.

(
ii)
Respondent
activities:
Page
12
Champions
conduct
the
following
activities
in
order
to
complete
and
submit
the
Champion
for
Change
Application
form:

°
Review
the
H2E
Champions
for
Change
Program
information
and
overall
H2E
Program
information;
°
Select
a
primary
contact
person
for
the
Champion
H2E
Program;
°
Complete
the
Champion
for
Change
Application
form,
including
obtaining
the
signature
of
a
senior
official;
°
Plan
and
implement
P2/
waste
reduction
activities,
and
recruit
other
facilities
to
adopt
similar
activities;
and
°
Fax
or
mail
the
form
to
EPA
or
submit
the
form
through
the
online
registration
system.

Awards
Application
Form
H2E
Partners
for
Change
and
Champions
for
Change
Program
participants
may
choose
to
complete
and
submit
to
EPA
a
standard,
one­
page
Awards
Application
Form
that
provides
basic
organization
information
and
designation
of
the
award
for
which
the
organization
is
applying.
In
addition,
award
applicants
are
required
to
describe
how
their
organization
has
met
the
evaluation
criteria
for
the
award.

(
i)
Data
items:

The
reporting
items
include:

°
Date
and
facility
name;
°
Name,
title,
department,
address,
phone
number,
fax
number,
and
e­
mail
address
of
the
organization's
primary
contact
person;
°
Indication
of
whether
or
not
the
organization
has
received
recognition
(
other
than
from
the
H2E
Program)
for
its
environmental
initiatives;
°
Award
for
which
the
application
is
being
submitted;
°
Checklist
of
actions
and
materials
required
to
complete
award
application
packet;
°
Signature
and
printed
name
of
contact
person.

(
ii)
Respondent
activities:

Participants
conduct
the
following
activities
in
order
to
complete
and
submit
the
Awards
Application
Form:

°
Select
one
of
the
following
awards
categories:
H2E
Partner
Recognition,
Making
Medicine
Mercury­
Free
Award,
H2E
Partners
for
Change
Award,
H2E
Environmental
Leadership
Award,
H2E
Champion
Award;
°
Complete
the
Awards
Application
Form;
°
Describe
how
their
organization
meets
the
evaluation
criteria
for
the
award
and
submit
checklist
if
applicable;
°
Submit
supporting
material
such
as
photographs,
newsletters,
fliers,
and
policies;
°
Fax
or
mail
the
form
and
supporting
materials
to
EPA.
Page
13
5.
THE
INFORMATION
COLLECTED
 
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
5(
a)
Agency
Activities
Under
the
H2E
Program,
EPA
engages
in
the
following
activities
related
to
the
four
reporting
forms:

Partner
Registration
and
Pledge
Form
°
Distribute
the
Partner
Registration
and
Pledge
Form
to
potential
participants,
maintain
a
downloadable
PDF
version
on
the
H2E
Web
site,
and
make
it
available
as
part
of
an
online
registration
system;
°
Answer
questions
posed
by
potential
participants
regarding
membership
in
the
Program;
and
°
Receive
completed
forms,
enter
information
into
a
database,
conduct
quality
assurance/
quality
control
(
QA/
QC)
on
data
entry,
and
place
a
welcome
call
to
the
new
Partner.

Annual
Facility
Assessment
Summary
and
Goals
Form
°
Distribute
the
Annual
Facility
Assessment
Summary
and
Goals
Form
to
program
Partners,
maintain
a
downloadable
PDF
version
on
the
H2E
Web
site,
and
make
it
available
as
part
of
an
online
reporting
system;
°
Maintain
a
tracking
system
and
develop/
revise
standard
data
reports;
°
Answer
questions
regarding
the
Annual
Facility
Assessment
Summary
and
Goals
Form;
°
Share
information
with
interested
Partners
on
possible
goals
for
their
organization;
°
Receive
the
completed
forms,
review
for
accuracy,
and
place
any
necessary
followup
calls;
°
Enter
information
into
a
database
and
conduct
QA/
QC
on
data
entry;
and
°
Develop
and
make
publicly
available
an
annual
summary
of
overall
program
progress
and
case
studies
of
highly
successful
programs.

Champion
for
Change
Application
form
°
Distribute
the
Champion
for
Change
Application
form
to
program
Partners,
maintain
a
downloadable
PDF
version
on
the
H2E
Web
site,
and
make
it
available
as
part
of
an
online
registration
system;

°
Answer
questions
posed
by
potential
Champions
regarding
membership
in
the
Program;
°
Receive
completed
forms,
enter
information
into
a
database,
conduct
QA/
QC
on
data
entry,
and
place
a
welcome
call
to
the
new
Champion.

Awards
Application
Form
°
Distribute
the
Awards
Application
Form
to
program
participants
when
requested
Page
14
and
maintain
a
downloadable
PDF
version
on
the
H2E
Web
site;
°
Answer
questions
posed
by
potential
award
applicants
regarding
the
awards
and
award
application
process;
°
Receive
completed
forms
and
supporting
materials
and
make
award
selections;
and
°
Notify
both
successful
and
unsuccessful
applicants
of
the
award
decisions.

5(
b)
Collection
Methodology
and
Management
Respondents
will
be
able
to
obtain
the
reporting
forms
in
hard
copy
from
EPA
or
by
downloading
them
from
the
H2E
Web
site.
The
completed
forms
can
be
faxed
or
mailed
to
EPA,
or
submitted
through
the
online
registration
system
that
is
planned
for
2004.

In
collecting
and
analyzing
the
information
associated
with
this
ICR,
EPA
uses
a
telephone
system,
personal
computers,
an
online
registration
and
reporting
system,
and
applicable
database
software.
EPA
ensures
the
accuracy
and
completeness
of
collected
information
by
reviewing
each
submittal.
EPA
enters
the
information
obtained
from
the
forms
into
a
database
and
conducts
QA/
QC
on
data
entry.
The
Agency
uses
software
to
aggregate
data
obtained
from
Annual
Facility
Assessment
Summary
and
Goals
Forms.
The
aggregate
data
is
used
to
identify
prominent
P2/
waste
reduction
strategies,
and
to
develop
and
publish
an
annual
summary
of
overall
Partner
progress
and
case
studies
of
highly
successful
P2/
waste
reduction
activities.

5(
c)
Small
Entity
Flexibility
EPA
expects
that
some
of
the
participants
in
the
H2E
Program
will
be
small
entities.
EPA
has
designed
its
reporting
forms
to
minimize
respondent
burden
while
obtaining
sufficient
and
accurate
information.
Reporting
will
be
further
facilitated
by
the
creation
of
an
online
registration
and
reporting
system,
which
is
planned
for
2004.
The
H2E
Program
was
designed
to
be
highly
flexible.
Organizations
can
choose
their
own
goals
based
on
individual
organization
needs
and
resources.
In
addition,
the
burden
associated
with
the
H2E
Program
is
inherently
reduced
since
the
initial
agreement
to
participate
is
voluntary.

5(
d)
Collection
Schedule
Organizations
may
submit
Partner
Registration
and
Pledge
Forms
to
join
the
H2E
Partners
for
Change
Program
at
any
time.
Within
six
months
after
a
participant
joins
the
Program,
it
should
submit
the
Annual
Facility
Assessment
Summary
and
Goals
Forms.
Annual
Facility
Assessment
Summary
and
Goals
Forms
are
also
due
to
EPA
by
January
31
of
every
subsequent
year
that
the
Partner
participates
in
the
Program,
unless
less
than
nine
months
have
passed
since
submittal
of
the
initial
form.
Organizations
may
submit
Champion
for
Change
Application
forms
to
join
the
H2E
Champions
for
Change
Program
at
any
time.
Partners
and
Champions
may
choose
to
apply
for
awards
by
submitting
the
Awards
Application
Form;
award
applications
are
due
January
1
of
each
year.

6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
6(
a)
Estimating
Respondent
Burden
Page
15
Exhibit
6.1
presents
the
burden
hours
and
costs
for
all
respondents
during
each
of
the
three
years
covered
under
this
ICR.

The
Partner
Registration
and
Pledge
Form
contains
basic
questions
and
only
applies
for
the
first
year,
thus
the
burden
is
expected
to
be
minimal.
The
overall
burden
is
estimated
to
be
1.7
hours
per
participant.
This
burden
level
is
an
estimate
based
on
EPA's
experience
with
other
voluntary
programs
and
based
on
the
advice
of
H2E
partnering
organizations.
Burden
hours
for
the
Partner
Registration
and
Pledge
Form
are
for
reporting
only.

Completing
the
Annual
Facility
Assessment
Summary
and
Goals
Form
involves
assessing
hospital
waste
and
developing
goals
and
a
system
to
track
progress.
The
annual
labor
burden
for
this
collection
activity
is
estimated
at
5.25
hours
per
participant
the
first
year
and
1.75
hours
per
participant
in
subsequent
years.
Burden
hours
for
the
Annual
Facility
Assessment
Summary
and
Goals
Form
are
largely
for
reporting
activities,
since
the
recordkeeping
activities
are
considered
to
be
customary
business
practices.

The
Champion
for
Change
Application
form
asks
for
basic
information
and
requests
brief/
general
descriptions
of
promotional
activities,
thus
the
burden
is
expected
to
be
minimal.
The
overall
burden,
as
shown
in
Exhibit
6.1,
is
estimated
to
be
2.7
hours
per
participant.
This
burden
level
is
based
on
EPA
experience
with
similar
voluntary
programs
and
based
on
the
advice
of
H2E
partnering
organizations.
All
burden
hours
for
the
Champion
for
Change
Application
form
are
for
reporting
only.
In
addition
to
answering
basic
questions
similar
to
those
listed
on
the
Partner
registration
and
pledge
form,
the
H2E
Champions
are
requested
to
describe
their
plans
for
and
implementation
of
P2/
waste
reduction
activities,
and
their
plans
to
recruit
other
facilities
to
adopt
similar
activities.
After
the
first
year,
Champions
will
be
asked
to
provide
an
informal
update
each
year
(
no
form
required)
regarding
the
ways
in
which
they
promote
the
H2E
Program
on
a
continued
basis.
EPA
estimates
that
the
burden
of
this
update
will
be
0.5
hours
per
Champion
per
year.

EPA
estimates
that
25
percent
of
Partners
and
Champions
will
apply
for
awards
each
year.
The
overall
burden
required
to
prepare
supporting
application
materials
and
to
complete
the
Awards
Application
Form
is
estimated
to
be
20
hours
per
applicant.

6(
b)
Estimating
Respondent
Costs
EPA
estimates
an
average
hourly
labor
rate
(
hourly
rate
plus
overhead)
of
$
60
for
managerial
staff,
$
35
for
technical
staff,
and
$
20
for
clerical
staff.
The
hourly
labor
rates
were
provided
by
the
Dartmouth
Hitchcock
Medical
Center
in
Lebanon,
New
Hampshire,
and
reflect
national
averages.
It
is
presumed
that
technical
staff
will
complete
80
percent
of
the
tasks
listed
in
Exhibit
6.1,
clerical
staff
will
complete
15
percent,
and
managerial
staff
will
complete
5
percent.

No
capital
or
operations
and
management
costs
are
incurred
by
respondents
under
this
ICR.

Exhibit
6.1.
Estimated
Annual
Burden
and
Costs
to
Respondents
Page
16
Collection
Activity
Estimated
#
of
Responses
Estimated
response
time
in
hours
TOTAL
BURDEN
TOTAL
COST
M
(
5%)
T
(
80%)
C
(
15%)
Total
Hours
Partner
Registration
Form
500
Review
Program
information
.5
12.5
200
37.5
250
$
8,500
Obtain
senior
approval
1
25
400
75
500
17,000
Complete
and
submit
form
.2
5
80
15
100
3,400
Subtotal
500
1.7
42.5
680
127.5
850
$
28,900
Annual
Facility
Assessment
Summary
and
Goals
Form
(
First
Year)
500
Review
H2E
Assessment
Guide
.5
12.5
200
37.5
250
$
8,500
Collect
data/
review
records
4
100
1,600
300
2,000
68,000
Complete
form
.25
6.25
100
18.75
125
4,250
Fax/
mail
form
to
EPA
.25
6.25
100
18.75
125
4,250
Respond
to
EPA
questions
.25
6.25
100
18.75
125
4,250
Subtotal
500
5.25
131.25
2,100
393.75
2,625
$
89,250
Annual
Facility
Assessment
Summary
and
Goals
Form
(
Subsequent
Years)
500
Review
previous
goals
and
set
new
goals
.5
12.5
200
37.5
250
$
8,500
Collect
data
.5
12.5
200
37.5
250
8,500
Complete
form
.25
6.25
100
18.75
125
4,250
Fax/
mail
form
to
EPA
.25
6.25
100
18.75
125
4,250
Respond
to
EPA
questions
.25
6.25
100
18.75
125
4,250
Subtotal
500
1.75
43.75
700
131.25
875
$
29,750
Champion
Application
Form
50
Review
Program
information
.5
1.25
20
3.75
25
$
850
Obtain
senior
approval
1
2.5
40
7.5
50
1,700
Identify
activities
1
2.5
40
7.5
50
1,700
Complete
and
submit
form
.2
.5
8
1.5
10
340
Subtotal
50
2.7
6.75
108
20.25
135
$
4,590
Awards
Application
Form
140
Select
award
category
.5
3.5
56
10.5
70
$
2,380
Complete
Form
.25
1.75
28
5.25
35
1,190
Describe
how
organization
meets
evaluation
criteria
18
126
2,016
378
2,520
85,680
Submit
supporting
materials
1
7
112
21
140
4,760
Fax/
mail
form
to
EPA
.25
1.75
28
5.25
35
1,190
Subtotal
140
20
140
2,240
420
2,800
$
95,200
YEAR
1
Partner
Registration
Form
500
1.7
42.5
680
127.5
850
$
28,900
Annual
Facility
Assessment
(
First
Year)
500
5.25
131.25
2,100
393.75
2,625
89,250
Page
17
Collection
Activity
Estimated
#
of
Responses
Estimated
response
time
in
hours
TOTAL
BURDEN
TOTAL
COST
M
(
5%)
T
(
80%)
C
(
15%)
Total
Hours
Champion
Application
Form
50
2.7
6.75
108
20.25
135
4,590
Awards
Application
Form
140
20
140
2,240
420
2,800
95,200
TOTAL
1,190
320.5
5,128
961.5
6,410
$
217,940
YEAR
2
Partner
Registration
Form
500
1.7
42.5
680
127.5
850
$
28,900
Annual
Facility
Assessment
(
First
Year)
500
5.25
131.25
2,100
393.75
2,625
89,250
Annual
Facility
Assessment
(
Subsequent
Year)
500
1.75
43.75
700
131.25
875
29,750
Champion
Application
Form
50
2.7
6.75
108
20.25
135
4,590
Champion
Update
50
.5
25
25
875
Awards
Application
Form
280
20
280
4,480
840
5,600
190,400
TOTAL
1,880
504.25
8,093
1,512.75
10,110
$
343,765
YEAR
3
Partner
Registration
Form
500
1.7
42.5
680
127.5
850
$
28,900
Annual
Facility
Assessment
(
First
Year)
500
5.25
131.25
2,100
393.75
2,625
89,250
Annual
Facility
Assessment
(
Subsequent
Year)
1,000
1.75
87.5
1,400
262.5
1,750
59,500
Champion
Application
Form
50
2.7
6.75
108
20.25
135
4,590
Champion
Update
100
.5
50
50
1,750
Awards
Application
Form
420
20
420
6,720
1,260
8,400
285,600
TOTAL
2,570
688
11,058
2,064
13,810
$
469,590
3­
YEAR
TOTAL
5,640
1,512.75
24,279
4,538.25
30,330
$
1,031,295
6(
c)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
Burden
EPA
estimates
that
over
the
three­
year
life
of
the
clearance,
1,500
hospitals
will
join
the
H2E
Program
and
complete
the
Partner
Registration
and
Pledge
Form
and
Annual
Facility
Assessment
Summary
and
Goals
Form.
In
addition,
150
Champions
will
complete
the
Champion
for
Change
Application
form
and
updates.
EPA
estimates
that
Partners
and
Champions
will
submit
approximately
840
awards
applications
over
the
three­
year
period.
The
total
burden
hours
associated
with
this
information
collection
is
30,330
hours
and
$
1,031,295.

6(
d)
Estimating
Agency
Burden
and
Costs
Exhibit
6.2
presents
the
estimated
Agency
burden
hours
and
costs
associated
with
the
information
collection
activities
under
this
ICR.
Other
direct
costs
(
copying,
printing,
telephone,
and
mailing
expenses)
are
also
included.
EPA
based
its
burden
estimates
on
its
experience
managing
other
voluntary
programs.

Based
on
the
general
schedule
(
GS)
pay
schedule,
EPA
estimates
an
average
hourly
labor
rate
(
hourly
rate
plus
the
standard
government
overhead
factor
of
1.6)
of
$
54
for
managerial
staff,
$
39
for
technical
staff,
and
$
18
for
clerical
staff.
The
Agency
expects
most
activities
to
be
Page
18
performed
by
managerial
staff
(
25
percent)
and
technical
staff
(
75
percent).
When
clerical
staff
is
utilized,
clerical
activities
will
constitute
one
percent
of
the
work
(
with
technical
staff
at
74
percent).

Exhibit
6.2.
Annual
Agency
Burden/
Cost
Activities
Hours
Other
Direct
Costs
TOTAL
COST
Partner
Pledge
and
Registration
Form
For
500
forms
Distribute
Forms
20
$
100
$
950
Answer
Questions
30
$
250
$
1,533
Record/
Enter
Forms
20
$
100
$
950
Mail
Partner
Packets
10
$
600
$
988
Subtotal
80
$
1,050
$
4,421
Annual
Facility
Assessment
and
Goals
Form
For
500
forms
Distribute
Form
20
$
100
$
950
Maintain
Database
40
$
100
$
1,800
Answer
Questions
30
$
250
$
1,533
Review
Submitted
Data
40
$
100
$
1,800
Enter/
QA
Data
in
Database
20
$
100
$
950
Develop
Report/
Share
Information
40
$
300
$
2,000
Subtotal
150
$
950
$
9,033
Champion
for
Change
Application
Form
For
50
forms
Distribute
Forms
3
$
10
$
217
Answer
Questions
10
$
150
$
578
Record/
Enter
Forms
4
$
75
$
246
Mail
Champion
Packets
4
$
60
$
455
Subtotal
21
$
295
$
1,496
Awards
Application
Form
For
140
forms
Distribute
Forms
8
$
28
$
368
Answer
Questions
20
$
200
$
1,050
Make
Award
Selections
10
$
150
$
575
Notify
Applicants
of
Decision
4
$
28
$
198
Subtotal
42
$
406
$
2,191
Year
1
Total
293
$
2,701
$
17,141
Year
2
Total
485
$
4,057
$
28,365
Year
3
Total
677
$
5,413
$
39,589
3­
Year
Total
1,455
$
12,171
$
85,095
Page
19
6(
e)
Bottom
Line
Burden
Hours
and
Cost
Tables
a.
Respondent
Tally
Exhibit
6.3.
Average
Annual
Estimated
Respondent
Burden
and
Cost
Summary
Average
#
of
Respondents
Average
Annual
Burden
Hours
Average
Annual
Cost
550
10,110
$
343,765
b.
Agency
Tally
Exhibit
6.4.
Average
Annual
Estimated
Agency
Burden
and
Cost
Summary
Annual
Burden
Hours
Annual
Cost
485
$
28,365
6(
f)
Reasons
for
Change
in
Burden
Since
this
is
a
new
ICR,
change
in
respondent
burden
is
not
applicable.

6(
g)
Burden
Statement
The
annual
public
burden
for
this
collection
of
information
is
estimated
to
range
between
0.5
and
20
hours
per
response,
depending
upon
the
type
of
information
the
respondent
provides.
According
to
the
Paperwork
Reduction
Act,
"
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.
For
this
collection
it
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
number
for
this
information
collection
appears
above.
The
OMB
control
numbers
for
EPA's
regulations
in
title
40
of
the
CFR,
after
appearing
in
the
Federal
Register,
are
listed
in
40
CFR
part
9
and
included
on
the
related
collection
instrument
or
form,
if
applicable.

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.
OPPT­
2002­
0036,
which
is
available
for
public
viewing
at
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
Pollution
Prevention
and
Toxics
Docket
is
(
202)
566­
0280.
An
Page
20
electronic
version
of
the
public
docket
is
available
through
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.
OPPT­
2002­
0036
in
any
correspondence.

ATTACHMENTS:

[
NOTE:
Unless
otherwise
noted,
an
electronic
copy
of
the
attachment
is
available
only
as
a
PDF
file.
You
can
still
easily
access
the
electronic
PDF
file
in
the
electronic
version
of
the
public
docket
available
through
EDOCKET
at
http://
www.
epa.
gov/
edocket.
Once
in
the
system,
select
"
quick
search,"
then
indicate
that
you'd
like
to
search
by
Docket
and
key
in
the
following
docket
ID
number:
OPPT­
2002­
0036.
Search
the
docket
index
for
this
document
by
the
title
provided
above.
If
you
have
any
difficulties,
please
contact
the
technical
person
listed
in
the
Federal
Register
notice
announcing
the
submission
of
this
ICR
to
OMB
for
review
and
approval.]

Attachment
Document
A
Memorandum
of
Understanding
Between
AHA
and
EPA
B
Letters
of
Support
C
Pollution
Prevention
Act
Section
6604(
b)(
5);
42
U.
S.
C.
13103(
b)(
5)
[
The
electronic
copy
for
this
attachment
is
available
as
part
of
the
electronic
copy
of
the
ICR's
Supporting
Statement.]

D
Partner
Registration
and
Pledge
Form
E
Annual
Facility
Assessment
Summary
and
Goals
Form
F
Champion
for
Change
Application
Form
G
Awards
Application
Form
H
Public
Comments
Received
During
Public
Notice
and
Comment
Period
and
EPA's
Response
to
Comments
[
The
electronic
copy
for
this
attachment
is
available
as
part
of
the
electronic
copy
of
the
ICR's
Supporting
Statement.]

I
Paperwork
Reduction
Act
Notice
[
The
electronic
copy
for
this
attachment
is
available
as
part
of
the
electronic
copy
of
the
ICR's
Supporting
Statement.]
ATTACHMENT
A
Memorandum
of
Understanding
Between
AHA
and
EPA
(
Note:
An
electronic
copy
of
this
attachment
is
available
only
as
a
PDF
file.
You
can
easily
access
this
file
in
the
electronic
version
of
the
public
docket
available
through
EDOCKET
at
http://
www.
epa.
gov/
edocket.
Once
in
the
system,
select
"
quick
search,"
then
indicate
that
you'd
like
to
search
by
Docket
and
key
in
the
following
docket
ID
number:
OPPT­
2002­
0036.
Search
the
docket
index
for
this
document
by
the
title
provided
above.
If
you
have
any
difficulties,
please
contact
the
technical
person
listed
in
the
Federal
Register
notice
announcing
the
submission
of
this
ICR
to
OMB
for
review
and
approval.)
ATTACHMENT
B
Letters
of
Support
(
Note:
An
electronic
copy
of
this
attachment
is
available
only
as
a
PDF
file.
You
can
easily
access
this
file
in
the
electronic
version
of
the
public
docket
available
through
EDOCKET
at
http://
www.
epa.
gov/
edocket.
Once
in
the
system,
select
"
quick
search,"
then
indicate
that
you'd
like
to
search
by
Docket
and
key
in
the
following
docket
ID
number:
OPPT­
2002­
0036.
Search
the
docket
index
for
this
document
by
the
title
provided
above.
If
you
have
any
difficulties,
please
contact
the
technical
person
listed
in
the
Federal
Register
notice
announcing
the
submission
of
this
ICR
to
OMB
for
review
and
approval.)
ATTACHMENT
C
Pollution
Prevention
Act
Section
6604(
b)(
5)

42
U.
S.
C.
13103(
b)(
5)

[
Electronic
copy
available
as
part
of
the
electronic
copy
of
the
ICR's
Supporting
Statement.]
U.
S.
Code
As
of
January
23,
2000
TITLE
42­­
THE
PUBLIC
HEALTH
AND
WELFARE
CHAPTER
133­­
POLLUTION
PREVENTION
Sec.
6604.
EPA
activities
*
*
*

b)
Functions
The
Administrator
shall
develop
and
implement
a
strategy
to
promote
source
reduction.
As
part
of
the
strategy,
the
Administrator
shall
 
*
*
*

(
5)
facilitate
the
adoption
of
source
reduction
techniques
by
businesses.
This
strategy
shall
include
the
use
of
the
Source
Reduction
Clearinghouse
and
State
matching
grants
provided
in
this
chapter
to
foster
the
exchange
of
information
regarding
source
reduction
techniques,
the
dissemination
of
such
information
to
businesses,
and
the
provision
of
technical
assistance
to
businesses.
The
strategy
shall
also
consider
the
capabilities
of
various
businesses
to
make
use
of
source
reduction
techniques
ATTACHMENT
D
Partner
Registration
and
Pledge
Form
Please
also
see
Attachment
I
­
Paperwork
Reduction
Act
Notice,
for
additional
information
that
will
accompany
the
form.
Once
approved
by
OMB,
the
OMB
Control
number
assigned
to
this
ICR
will
also
be
included
in
the
upper
right
corner
of
the
form,
i.
e.,
"
Approved
under
OMB
Control
No.
2070­[
insert
#
assigned
by
OMB);
OMB
Approval
expires
[
insert
ICR
expiration
date]."

(
Note:
An
electronic
copy
of
this
attachment
is
available
only
as
a
PDF
file.
You
can
easily
access
this
file
in
the
electronic
version
of
the
public
docket
available
through
EDOCKET
at
http://
www.
epa.
gov/
edocket.
Once
in
the
system,
select
"
quick
search,"
then
indicate
that
you'd
like
to
search
by
Docket
and
key
in
the
following
docket
ID
number:
OPPT­
2002­
0036.
Search
the
docket
index
for
this
document
by
the
title
provided
above.
If
you
have
any
difficulties,
please
contact
the
technical
person
listed
in
the
Federal
Register
notice
announcing
the
submission
of
this
ICR
to
OMB
for
review
and
approval.)
ATTACHMENT
E
Annual
Facility
Assessment
Summary
and
Goals
Form
Please
also
see
Attachment
I
­
Paperwork
Reduction
Act
Notice,
for
additional
information
that
will
accompany
the
form.
Once
approved
by
OMB,
the
OMB
Control
number
assigned
to
this
ICR
will
also
be
included
in
the
upper
right
corner
of
the
form,
i.
e.,
"
Approved
under
OMB
Control
No.
2070­[
insert
#
assigned
by
OMB);
OMB
Approval
expires
[
insert
ICR
expiration
date]."

(
Note:
An
electronic
copy
of
this
attachment
is
available
only
as
a
PDF
file.
You
can
easily
access
this
file
in
the
electronic
version
of
the
public
docket
available
through
EDOCKET
at
http://
www.
epa.
gov/
edocket.
Once
in
the
system,
select
"
quick
search,"
then
indicate
that
you'd
like
to
search
by
Docket
and
key
in
the
following
docket
ID
number:
OPPT­
2002­
0036.
Search
the
docket
index
for
this
document
by
the
title
provided
above.
If
you
have
any
difficulties,
please
contact
the
technical
person
listed
in
the
Federal
Register
notice
announcing
the
submission
of
this
ICR
to
OMB
for
review
and
approval.)
ATTACHMENT
F
Champion
for
Change
Application
Form
Please
also
see
Attachment
I
­
Paperwork
Reduction
Act
Notice,
for
additional
information
that
will
accompany
the
form.
Once
approved
by
OMB,
the
OMB
Control
number
assigned
to
this
ICR
will
also
be
included
in
the
upper
right
corner
of
the
form,
i.
e.,
"
Approved
under
OMB
Control
No.
2070­[
insert
#
assigned
by
OMB);
OMB
Approval
expires
[
insert
ICR
expiration
date]."

(
Note:
An
electronic
copy
of
this
attachment
is
available
only
as
a
PDF
file.
You
can
easily
access
this
file
in
the
electronic
version
of
the
public
docket
available
through
EDOCKET
at
http://
www.
epa.
gov/
edocket.
Once
in
the
system,
select
"
quick
search,"
then
indicate
that
you'd
like
to
search
by
Docket
and
key
in
the
following
docket
ID
number:
OPPT­
2002­
0036.
Search
the
docket
index
for
this
document
by
the
title
provided
above.
If
you
have
any
difficulties,
please
contact
the
technical
person
listed
in
the
Federal
Register
notice
announcing
the
submission
of
this
ICR
to
OMB
for
review
and
approval.)
ATTACHMENT
G
Awards
Application
Form
Please
also
see
Attachment
I
­
Paperwork
Reduction
Act
Notice,
for
additional
information
that
will
accompany
the
form.
Once
approved
by
OMB,
the
OMB
Control
number
assigned
to
this
ICR
will
also
be
included
in
the
upper
right
corner
of
the
form,
i.
e.,
"
Approved
under
OMB
Control
No.
2070­[
insert
#
assigned
by
OMB);
OMB
Approval
expires
[
insert
ICR
expiration
date]."

(
Note:
An
electronic
copy
of
this
attachment
is
available
only
as
a
PDF
file.
You
can
easily
access
this
file
in
the
electronic
version
of
the
public
docket
available
through
EDOCKET
at
http://
www.
epa.
gov/
edocket.
Once
in
the
system,
select
"
quick
search,"
then
indicate
that
you'd
like
to
search
by
Docket
and
key
in
the
following
docket
ID
number:
OPPT­
2002­
0036.
Search
the
docket
index
for
this
document
by
the
title
provided
above.
If
you
have
any
difficulties,
please
contact
the
technical
person
listed
in
the
Federal
Register
notice
announcing
the
submission
of
this
ICR
to
OMB
for
review
and
approval.)
ATTACHMENT
H
Public
Comments
Received
During
Public
Notice
and
Comment
Period
and
EPA's
Response
to
Comments
[
Electronic
copy
available
as
part
of
the
electronic
copy
of
the
ICR's
Supporting
Statement.]
PUBLIC
COMMENTS
RECEIVED
DURING
PUBLIC
NOTICE
AND
COMMENT
PERIOD
AND
EPA'S
RESPONSE
TO
COMMENTS
PART
A
­
SUMMARY
OF
PUBLIC
COMMENTS
RECEIVED
The
following
is
a
summary
of
the
public
comments
submitted
to
EPA
during
the
comment
period
for
this
new
ICR.
Although
electronic
copies
of
the
original
comments
are
not
available,
you
may
view
the
paper
copies
at
the
EPA
Docket
Center
as
described
in
the
Federal
Register
notice
announcing
the
submission
of
this
ICR
to
OMB.
You
can
also
access
location
information
through
EDOCKET
at
http://
www.
epa.
gov/
edocket.
Once
in
the
system,
select
"
quick
search,"
then
indicate
that
you'd
like
to
search
by
Docket
and
key
in
the
following
docket
ID
number:
OPPT­
2002­
0036.

Document
ID
No.
OPPT­
2002­
0036­
0003
Comment:
The
NH
Association
has
been
a
H2E
participant
since
the
inception
of
the
program
and
is
currently
a
Champion
for
Change
participant.
The
Association
fully
supports
EPA
request
to
collect
information
on
healthcare
facilities
that
participate
in
the
H2E
program.

Document
ID
No.
OPPT­
2002­
0036­
0004
Comment:
Columbia
St.
Mary's
Hospital
has
been
a
H2E
participant
since
2001,
and
is
currently
a
Partner
for
Change
participant.
St.
Mary's
fully
support
EPA's
request
to
collect
information
on
healthcare
facilities
that
participate
in
the
H2E
program.

Document
ID
No.
OPPT­
2002­
0036­
0005
Comment:
The
Mills
Peninsula
Health
Services
has
been
a
H2E
participant
since
2001,
and
is
currently
a
Partner
for
Change
participant.
Mills
Peninsula
fully
supports
EPA's
request
to
collect
information
on
healthcare
facilities
that
participate
in
the
H2E
program.

Document
ID
No.
OPPT­
2002­
0036­
0006
Comment:
The
Center
for
Environmental
Health
has
been
a
H2E
program
participant
since
November
2001,
and
is
currently
a
Champion
for
Change
participant.
The
Center
fully
support
EPA's
request
to
collect
information
on
healthcare
facilities
that
participate
in
the
H2E
program.

Document
ID
No.
OPPT­
2002­
0036­
0007
Comment
5:
The
City
of
Albuquerque's
Public
Works
Department
has
been
a
H2E
participant
since
2001,
and
is
currently
a
Champion
for
Change
participant.
The
Department
fully
support
EPA's
request
to
collect
information
on
healthcare
facilities
that
participate
in
the
H2E
program.

Document
ID
No.
OPPT­
2002­
0036­
0008
Comment:
The
American
Nurses
Association
has
been
a
H2E
program
participant
since
1998,
and
is
currently
one
of
the
four
partners
with
EPA,
the
American
Hospital
Association
and
Health
Care
Without
Harm.
The
Association
support
EPA's
request
to
collect
information
on
healthcare
facilities
that
participate
in
the
H2E
program.

Document
ID
No.
OPPT­
2002­
0036­
0009
Comment:
The
Minnesota
Technical
Assistance
Program
(
MnTAP)
has
been
a
H2E
program
participant
since
1998,
and
is
currently
a
Champion
for
Change
participant.
MnTAP
fully
support
EPA's
request
to
collect
information
on
healthcare
facilities
that
participate
in
the
H2E
program.

PART
B
­
EPA'S
RESPONSE
TO
COMMENTS
All
of
the
comments
received
on
this
ICR
during
the
public
comment
period
were
supportive
of
the
ICR
as
written.
We
have
therefore
made
no
substantive
changes
to
the
ICR.
ATTACHMENT
I
Paperwork
Reduction
Act
Notice
Under
5
CFR
1320.8(
c)(
1),
the
Agency
is
required
to
provide
reasonable
notice
to
potential
respondents
that
informs
them
about
the
information
collection
activity
and
OMB's
approval.
As
such,
pursuant
to
5
CFR
1320.8(
c)(
1)(
i),
the
following
statement
will
be
included
with
each
form,
either
on
the
form,
as
part
of
the
instructions,
or
in
the
cover
letter
or
memorandum
accompanying
the
form,
and,
pursuant
to
5
CFR
1320.8(
c)(
1)(
ii),
the
following
statement
will
be
included
as
a
pop­
up
message
that
the
respondent
will
encounter
before
they
access
the
associated
form(
s)
on­
line.
Once
the
forms
are
approved
by
OMB,
the
OMB
Control
number
assigned
to
this
ICR
will
also
be
included
in
the
upper
right
corner
of
the
form,
i.
e.,
"
Approved
under
OMB
Control
No.
2070­[
insert
#
assigned
by
OMB);
OMB
Approval
expires
[
insert
ICR
expiration
date]."

This
statement
will
be
modified
as
indicated
for
use
with
the
associated
form(
s).

[
Electronic
copy
available
as
part
of
the
electronic
copy
of
the
ICR's
Supporting
Statement.]
Paperwork
Reduction
Act
Notice:

The
annual
public
burden
for
this
collection
of
information,
which
is
approved
under
OMB
Control
No.
2070­
XXXX[#
will
be
inserted
after
OMB
approval
and
before
use],
is
estimated
to
be
##
hours
[
Since
the
total
ICR
burden
is
estimated
to
range
between
0.5
and
20
hours
per
response,
the
entry
for
each
form
will
be
inserted
and
fit
within
this
range.]
per
response.
This
represents
the
average
burden
for
completing
this
form,
including
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;
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
subject
to
approval
under
the
PRA
unless
it
displays
a
currently
valid
OMB
control
number.
The
OMB
control
number
for
this
information
collection
appears
above
and
on
the
forms.
Comments
on
this
information
collection
activity
or
EPA's
burden
estimates
may
be
submitted
EPA
online
at
http://
www.
epa.
gov/
edocket
(
our
preferred
method)
or
by
mail
to:
EPA
Docket
Center,
Environmental
Protection
Agency,
Mailcode:
7407T,
1200
Pennsylvania
Ave.,
NW,
Washington,
DC
20460.
Once
in
the
system,
select
"
search,"
then
key
in
the
Docket
ID
No.
OPPT­
2002­
0036.
Do
not
submit
any
completed
forms
to
the
docket.
Completed
forms
should
be
submitted
in
accordance
with
the
instructions
provided
with
each
form.
