  SEQ CHAPTER \h \r 1 Supporting Statement for a Request for OMB Review
under

The Paperwork Reduction Act

1	IDENTIFICATION OF THE INFORMATION COLLECTION

1(a)	Title and Number of the Information Collection

	Title:	Reporting Requirements under EPA’s Safer Detergent Stewardship
Initiative (SDSI) Program

		EPA ICR No.: TBD.01	OMB Control No.: 2070-TBD

1(b)	Short Characterization

EPA is developing the SDSI to recognize environmental leaders who
voluntarily commit to the use of safer surfactants.  Leading chemical
manufacturers have made great progress in developing safer, highly
effective surfactants.  As a result, some leading U.S. corporations that
formulate products with surfactants, such as cleaning products, have
been able to act in advance of SDSI to use safer surfactants in their
product lines.  Stakeholders who have reformulated products using safer
surfactants have called the change cost-neutral.  SDSI would encourage a
shift to safer surfactants by companies unaware of the benefits of such
a change.  SDSI would also attract companies that see value in the
public recognition of corporate product stewardship that SDSI will
provide.

Surfactants are used in a wide variety of applications and products. 
Examples include detergents, cleaners, airplane deicers, and
fire-fighting foams.  Products such as paint and ink that also use
surfactants were not included in the scope of SDSI based on
recommendations from industry, environmental groups, and others. 
Stakeholders suggested that EPA could drive the most significant
environmental improvement at the lowest possible cost by focusing SDSI
on encouraging safer surfactants for products whose use routinely
results in their discharge to the environment.  Safer surfactants are
surfactants that break down quickly to non-polluting compounds.
Nonylphenol ethoxylates, commonly referred to as NPEs, are an example of
a surfactant class that does not meet this definition.  Both NPEs and
their breakdown products, such as nonylphenol, are toxic to aquatic
life. 

EPA published the Aquatic Life Ambient Water Quality Criteria for
Nonylphenol in the Federal Register in February 2006. The Safer
Detergents Stewardship Initiative will complement EPA’s Aquatic Life
Criteria, by encouraging the manufacture and use of safer surfactants,
thus reducing the amount of nonylphenol ethoxylate surfactants and
nonylphenol in streams and other water bodies.  The Design for the
Environment (DfE) program has identified safer alternatives to NPE
surfactants through its partnership work with industry and environmental
advocates; many are comparable in cost and are readily available.  

There are two categories for recognition under SDSI: Champion and
Partner. Champion is the highest level of recognition offered under
SDSI.  At this level, the participant is invited to the SDSI Awards
ceremony, is listed on the EPA SDSI Web site as a Champion, and may use
a special logo in their literature to help explain their participation
in the program.  The Partner category provides recognition of
significant accomplishment towards the use of safer surfactants. 
Partners will be listed on the EPA SDSI Web site and may be granted
recognition as a Champion in the future, if appropriate.

Both Champions and Partners will receive a certificate of recognition
from DfE.  To be eligible for the awards ceremony, which will be held in
the summer of 2008, candidates for Champion status should submit their
application by December 31, 2007.  The application for participating in
SDSI will be available on the SDSI Web page in the fall of 2007.

EPA will also specify the following general requirements:

Candidates should post a statement on their Web site describing the
actions that qualify them for recognition under SDSI; and

Candidates should complete an application and have it signed by a
company authority (e.g., Chief Executive Officer, or vice president with
responsibility for product formulation).  The application would describe
the actions taken to qualify for recognition.

EPA will use available information resources to track the progress of
the program, both in terms of the level of participation and expected
environmental benefits.  A cleaning industry trade association plans to
apply for recognition as a Champion under SDSI.  In order to qualify for
this level of recognition, the association plans to monitor the number
of its product manufacturer members participating in SDSI and to
correlate this number to an approximate percentage of the industry as a
whole.  For environmental benefits, EPA will use its own Inventory
Update Rule to establish a baseline and track changes in the levels of
nonylphenol ethoxylate manufactured, imported and used in the U.S.  EPA
may also make use of ongoing studies that monitor the level of
contaminants, like nonylphenol, in various water bodies and sediment. 
EPA will review information sources for endpoints such as level of
program participation, trends in surfactant use, and levels of toxic
surfactant degradates in waters and sediment.  EPA will evaluate whether
there is a correlation between SDSI participation and environmental
outcomes.

  SEQ CHAPTER \h \r 1 2.	NEED FOR AND USE OF THE COLLECTION

	2(a)	Need/Authority for the Collection

Authority for SDSI derives from two statutory sources.  Section
6604(b)(5) of the Pollution Prevention Act (PPA, 42 U.S.C. 13103(b)(5);
see Attachment A) directs EPA to facilitate the adoption of
source-reduction techniques by businesses.  Section 6604(b)(13) directs
EPA to establish an annual awards program to recognize a company or
companies that operate outstanding or innovative source reduction
programs.  In recognition of these directives, and through consultation
with a broad range of stakeholders, EPA developed SDSI.  In addition,
the SDSI Program complements the Aquatic Life Criteria for Nonylphenol
issued under authority of Section 304(a)(1) of the Clean Water Act on
February 23, 2006.  

SDSI’s information collection activities will assist the Agency in
meeting the goals of the PPA by providing resources and recognition for
businesses committed to promoting and using safer surfactants.  In turn,
SDSI will help businesses meet their corporate sustainability goals by
providing the means to, and an objective measure of, environmental
stewardship. Investment analysts and advisers seek these types of
measures in evaluating a corporation’s sustainability profile and
investment worthiness.  It is not surprising then that EPA has heard
from many organizations that the SDSI Program will be an important
impetus for prioritizing and completing the transition to safer
surfactants.  SDSI is also needed to promote greater use of safer
surfactants by companies unaware of the benefits of such a change.

EPA has carefully tailored its request for information, and especially
the SDSI Application Form, to ensure that it only asks for information
essential to verifying an applicants’ eligibility for award or
recognition.  

  SEQ CHAPTER \h \r 1 	2(b)	Practical Utility/Users of the Data

The information collected by the SDSI Program is not designed or
intended to support regulatory decision-making by EPA. EPA uses the
information collected in the SDSI Application Form to: (1) identify the
candidate’s commitment to promoting and using safer surfactants; (2)
verify the candidate’s involvement in promoting and using safer
surfactants; and (3) determine the candidate’s eligibility for award
or recognition under SDSI. 

  SEQ CHAPTER \h \r 1 3.     	NON-DUPLICATION, CONSULTATIONS, AND OTHER
COLLECTION 

        	CRITERIA

	3(a)	Non-Duplication

Respondents will not be asked to provide information that has been or is
currently being collected by EPA, other federal or state agencies or
proprietary sources. The information collected by the SDSI Program is
unique and is not duplicative of previous information collection
requests.  As due diligence, EPA also checked with trade associations
and potential partners to confirm that the information being collected
by the SDSI Program does not exist elsewhere.

  SEQ CHAPTER \h \r 1 	3(b)	Public Notice Required Prior to ICR
Submission to OMB

  SEQ CHAPTER \h \r 1  Prior to submission to OMB, this ICR will be made
available to the public for comment through a Federal Register notice. 
The public will have 60 days to provide comments.  Any comments received
will be given consideration when completing the supporting statement
that is submitted to OMB.

  SEQ CHAPTER \h \r 1 	3(c)	Consultations

Although the recognition program covered by this ICR has not started,
EPA announced its intentions to develop the SDSI Program in February
2006.  Since that time, EPA has received significant feedback on the
SDSI Program from stakeholders.  EPA continues to work closely with
stakeholders that include surfactant manufacturers, cleaning product
formulators, environmentalists, water treatment facilities, and cleaning
industry trade associations.

On June 12, 2006, DfE held a public meeting to take comments on SDSI. 
Ephraim King (Director of EPA’s Office of Science and Technology in
the Office of Water) and Charlie Auer (Director of EPA’s Office of
Pollution Prevention and Toxics in the Office of Prevention, Pesticides,
and Toxic Substances) provided overviews of EPA’s Aquatic Life
Criteria for Nonylphenol and SDSI.  A clear majority of stakeholders
representing a broad range of interests – surfactant manufacturers,
cleaning product formulators, environmentalists, a water treatment
facility, and a cleaning industry trade association – expressed strong
support for SDSI.  Following is a list of the stakeholders who spoke to
express support for the program at the public meeting:

Paul Anastas, Green Chemistry Institute 

Bill Balek, ISSA

Bill Greggs, Procter & Gamble	

Cory Hammock, Clean Control	

Marsha Hardin, Reckitt Benckiser	

Lauren Heine, GreenBlue	

Ed Hopkins, Sierra Club

Jennifer Jackson, East Bay Municipal Utility District

Jack Linard, Unilever 

Rich Liroff, World Wildlife Fund

David Long, SC Johnson 

Roger McFadden, Coastwide Chemicals

Sam Moore, Burlington Chemical	

A minority of stakeholders, representing the Alkylphenol Ethoxylate
Research Council (APERC), alkylphenol ethoxylate (APE) and alkylphenol
(AP) manufacturers, and two laundry trade associations (large APE
users), expressed concerns about SDSI.  Their concerns are summarized in
the June 12 public meeting notes published in the Federal Register (see
http://www.regulations.gov, document number: EPA-HQ-OPPT-2006-0343-0002,
docket number: EPA-HQ-OPPT-2006-0343).  EPA has taken steps to
ameliorate these concerns. These include (1) clarifying that the intent
of the program is to encourage the use of safer surfactants; the use of
any surfactants (not solely NPE surfactants) that degrade to long-lived
and more toxic degradates would disqualify an applicant from
recognition; (2) requiring that a company eligible for recognition have
a product stewardship strategy to ensure the use of safer surfactants;
and (3) limiting the scope of the program to those products whose use
routinely results in their discharge to the environment; products such
as ink, paint, and oil are not included.

Specifically regarding this ICR, EPA consulted with the following
potential respondents to obtain feedback on the need for the collection,
the reasonableness of the burden estimates, and alternative approaches
to collecting the information:

Bill Balek, ISSA (a trade association for the cleaning industry),
1-800-225-4772

John Barrett, KIMCO Corporation, 708-583-9800

Carol Chapin, Simple Green, 562-795-6000

Cory Hammock, Clean Control, 478-922-5340

Robert Israel, JohnsonDiversey, 262-631-4437

Roger McFadden, Coastwide Laboratories, 503-218-4900

Candice Rushton, Betco, 419-725-3833

Barbara Whitstone, CleanPower, 414-302-3000

In general, the individuals were supportive of the ICR and said the
burden estimates appeared reasonable.  Therefore, EPA made no changes to
the information in this supporting statement.

  SEQ CHAPTER \h \r 1 	3(d)	Effects of Less Frequent Collection

The SDSI Application Form is designed to be a one-time information
submission for organizations that wish to participate in the SDSI
Program as either a Partner or Champion.  In some instances, an
organization that applies for Partner recognition may choose to re-apply
at a later date for Champion recognition.  Without this information, EPA
will not be able to effectively determine whether companies are
switching to safer surfactants nor recognize companies who successfully
transition to safer surfactants.

  SEQ CHAPTER \h \r 1 	3(e)	General Guidelines

The information collection activities discussed in this renewal ICR
comply with all regulatory guidelines under 5 CFR 1320.5(d)(2).  

  SEQ CHAPTER \h \r 1 	3(f)	Confidentiality

No information collected by EPA under SDSI comprises confidential
business information.

  SEQ CHAPTER \h \r 1 	3(g)	Sensitive Questions

The information collection activities discussed in this document do not
involve any sensitive questions.

  SEQ CHAPTER \h \r 1 4.	THE RESPONDENTS AND THE INFORMATION REQUESTED

	4(a)	Respondents and NAICS Codes

SDSI seeks partners from establishments engaged in the production or use
of surfactants, as well as establishments involved in the purchasing,
distribution or use of products containing surfactants, whose use
routinely results in their discharge to the environment.  Others (e.g.,
non-profit organizations, unions, academia) may also qualify through
active encouragement of the use of safer surfactants.

Below is a list of North American Industry Classification System (NAICS)
codes and associated industries that may be affected by information
collection requirements covered under this ICR.  This list is intended
to be illustrative; entities from other industries may elect to apply
for recognition through SDSI.  However, EPA expects that most
applications will come from the following industries:

NAICS Code	Affected Industry

3256	Soap, Cleaning Compound, and Toilet Preparation Manufacturing

424490	Other Grocery and Related Products Merchant Wholesalers 

424690	Other Chemical and Allied Products Merchant Wholesalers

424990	Other Miscellaneous Nondurable Goods Merchant Wholesalers

4451	Grocery Stores

481	Air Transportation

561210	Facilities Support Services

561720	Janitorial Services

561740	Carpet and Upholstery Cleaning Services

611310	Colleges, Universities, and Professional Schools

7211	Traveler Accommodation

8123	Drycleaning and Laundry Services



	4(b)	Information Requested

Once a prospective organization reviews the SDSI materials and decides
to apply, it should submit a SDSI Application Form (see Attachment B for
complete form).  Applications will be received on an ongoing basis over
the three years covered by this ICR.  However, to be eligible for the
awards ceremony, which will be held in the summer of 2008, candidates
should submit their application by December 31, 2007.  Only candidates
for recognition at the champion level are eligible for the awards
ceremony.

All forms will be 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 SDSI Web site.

Data items:

The reporting items include:

Facility name and Web site URL;

Name, title, address, phone number, fax number, and e-mail address of
the candidate’s primary contact person;

Status (partner or champion) for which the candidate is applying;

Type of organization (e.g. manufacturing, purchasing, retail);

Description of facility and any relevant affiliations;

Descriptions of actions taken to qualify for recognition;

Relevant supporting documentation showing one or more of the following
(requirements vary by organization type / recognition level): evidence
of a full or intended transition to safer surfactants; a strategy to
ensure that only safer surfactants are used or purchased by specified
dates; a written commitment to a full transition to safer surfactants
within a specific time period; activities taken to date to promote the
use of safer surfactants

Where applicable, total production or use volume of surfactants

Signature, name, and title of senior company authority (e.g., CEO, or
vice president for health and environment).

Respondent activities:

Candidates conduct the following activities in order to complete and
submit the SDSI Application Form:

Review the SDSI information;

Decide whether to apply for recognition, and whether to apply for
partner or champion status;

Select a primary contact person for the program;

Complete the SDSI Application Form, including obtaining the signature of
a company authority (e.g., CEO or vice president for health and
environment);

Describe how their organization meets the evaluation criteria for the
relevant recognition;

Fax or mail the form to EPA;

Provide relevant documentation to EPA upon request.

  SEQ CHAPTER \h \r 1 5.      	THE INFORMATION COLLECTED – AGENCY
ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT

5(a)	Agency Activities

Under SDSI, EPA engages in the following activities related to the SDSI
Application Form:

Distribute the SDSI Application Form to potential participants, and
maintain a downloadable PDF version on the SDSI Web site;

Answer questions posed by potential applicants regarding recognition
under the Initiative; 

Receive the completed forms, review for accuracy, and place any
necessary follow-up calls; and

Approve candidates for recognition and notify both successful and
unsuccessful applicants of the decisions.

  SEQ CHAPTER \h \r 1 	5(b)	Collection Methodology and Management

Respondents will be able to obtain the SDSI Application Form in hard
copy from EPA or by downloading it from the SDSI Web site.  The
completed forms can be faxed or mailed to EPA.

In collecting and analyzing the information associated with this ICR,
EPA will use a telephone system, personal computers, and applicable
database software.  EPA will ensure the accuracy and completeness of
collected information by reserving the right to request the list of
ingredients (e.g., bills of lading, invoices) or other relevant
documentation at any time to confirm that candidates have the achieved
the criteria for recognition.  

  SEQ CHAPTER \h \r 1 	5(c)	Small Entity Flexibility

EPA expects that some of the participants in the SDSI program will be
small entities. EPA has designed its application form to minimize
respondent burden while obtaining sufficient and accurate information. 
In addition, given the voluntary nature of the collection, EPA expects
that respondents will participate only if the benefits of participation
outweigh the information collection burden.

  SEQ CHAPTER \h \r 1 	5(d)	Collection Schedule

Organizations may submit a one-time application for recognition as
Partners or Champions at any time.  To be eligible for the awards
ceremony, which will be held in the summer of 2008, candidates for
Champion status should submit their application by December 31, 2007.

  SEQ CHAPTER \h \r 1 6.	ESTIMATING THE BURDEN AND COST OF THE
COLLECTION

  SEQ CHAPTER \h \r 1 Exhibit 6.1 presents the estimated burden hours
and costs for all respondents during each of the three years covered
under this ICR.

The data collection mechanism for SDSI is the SDSI Application Form.  In
an effort to minimize burden and cost, the SDSI Application Form was
designed to contain straightforward questions.  It was also designed in
a way that one application package will serve all types of participants.
 The expected participant categories for SDSI are as follows:  chemical
manufacturers, formulators, retailers / distributors, institutional
purchasers, and “others” (e.g., non-profits, unions, and academia). 
Within these participant categories, it is expected that the chemical
manufacturers, formulators, retailers / distributors, and institutional
purchasers will be private sector institutions.  Within the participant
category “others,” about ten local governments (e.g., municipal
water supply systems) are likely to participate, with the remaining
participants being private sector institutions.  

	6(a)	Estimating Respondent Burden

The average respondent burden is estimated to be 10 hours for all
participant types (see Exhibit 6.1).  EPA used professional judgment to
arrive at a burden estimate and then consulted representatives from the
participant categories to make sure the burden estimate was reasonable
(see section 3(c)).  Burden hours for the SDSI application package are
for reporting purposes only.  

We expect that for a typical entity, program and application review will
take about one hour (technical staff).  Obtaining approval, which is
likely to involve verifying assumptions with staff and ensuring support
from multiple levels of management, will take about three hours (1
managerial, 1 technical, 1 clerical).  Completing the application form
will take about 6 hours (5 technical, 1 clerical) given the data
reporting requirements (see SDSI Application Form, Attachment B). 
Included in this estimate of 6 hours is the potential burden that would
be incurred if EPA finds it necessary to verify the information in the
application.  the purposes of the burden estimate, EPA assumes that it
will need to verify information from one organization in each
participant category.  This burden, when distributed among all
participants, is about 32 minutes per participant ((40 hrs x 5
participants) / 375 total participants).

	6(b)	Estimating Respondent Costs

EPA estimates an average hourly labor rate (base hourly rate plus fringe
and overhead) of $64 for managerial staff, $53 for technical staff, and
$26 for clerical staff.  These three labor rate estimates are taken from
manufacturing industry data in “Economic Analysis of Expedited
Significant New Use Rules for 66 Chemical Substances,” 12/06, p. B-4
(EPA Docket EPA-HQ-OPPT-2003-0063).  The type of staff needed to
complete the SDSI Application Form and their associated hourly labor
rates were verified by contacting representatives from the participant
categories.

In exhibit 6.1 we show the breakdown of burden costs, assuming 10 hours
for all participant categories.  No capital or operations and management
costs are incurred by respondents under this ICR, with the possible
exception of postage and photocopy costs.

  SEQ CHAPTER \h \r 1 Exhibit 6.1.  Estimated Burden and Costs to
Respondents

  SEQ CHAPTER \h \r 1 Type of Affected Public	Collection activity

Estimated response time (hours)	Total burden (hours)	Hourly labor cost
Total cost



	M	T 	C	M	T 	C	Total 	M	T 	C

	Private Sector	Chemical Manufacturers	37



	Review application and program information

0	1	0	0	37	0	37	$64	$53	$26	$1,961

	Obtain senior approval

1	1	1	37	37	37	111	$64	$53	$26	$5,291 

	Complete and submit package

0	5	1	0	185	37	222	$64	$53	$26	$10,767 

	Subtotal	37	1	7	2	37	259	74	370	--	--	--	$18,019 

	Formulators	206

 

	Review application and program information

0	1	0	0	206	0	206	$64	$53	$26	$10,918 

	Obtain senior approval

1	1	1	206	206	206	618	$64	$53	$26	$29,458 

	Complete and submit package1

0	5	1	0	1030	206	1236	$64	$53	$26	$59,946 

	Subtotal	206	1	7	2	206	1442	412	2060	--	--	--	$100,322

	Retailers / Distributors	23

 

	Review application and program information

0	1	0	0	23	0	23	$64	$53	$26	$1,219 

	Obtain senior approval

1	1	1	23	23	23	69	$64	$53	$26	$3,289

	Complete and submit package1

0	5	1	0	115	23	138	$64	$53	$26	$6,693 

	Subtotal	23	1	7	2	23	161	46	230	--	--	--	$11,201

	Institutional Purchasers	23

 

	Review application and program information

0	1	0	0	23	0	23	$64	$53	$26	$1,219 

	Obtain senior approval

1	1	1	23	23	23	69	$64	$53	$26	$3,289

	Complete and submit package1

0	5	1	0	115	23	138	$64	$53	$26	$6,693 

	Subtotal	23	1	7	2	23	161	46	230	--	--	--	$11,201

Private Sector and 

Local Governments	Others (e.g. non-profits, unions, academia)	86

 

	Review application and program information

0	1	0	0	86	0	86	$64	$53	$26	$4,558 

	Obtain senior approval

1	1	1	86	86	86	258	$64	$53	$26	$12,298 

	Complete and submit package1

0	5	1	0	430	86	516	$64	$53	$26	$25,026 

	Subtotal	86	1	7	2	86	602	172	860	--	--	--	$41,882 

	Total	375





	3750



$182,625



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

EPA estimates that 375 applications will be submitted over the
three-year life of the clearance.  This estimate is based on the
assumption that about 300 participants will apply for recognition under
SDSI – 150 for Partner recognition and 150 for Champion recognition
– and that roughly half of the 150 participants who apply for Partner
recognition (or 75) will apply at a later time for Champion recognition.
 The estimate of 300 participants assumes that twice the number of
organizations that have expressed interest in SDSI will ultimately
participate (to date, 140 different organizations have expressed
interest).  Furthermore, due to the nature of SDSI and the demographic
of interested parties, EPA estimates that about 55% of participating
companies will be formulators, 10% chemical manufacturers, 6% retailers
/ distributors, 6% institutional purchasers, and 23% others.  The total
burden hours and cost associated with this information collection are
4986 hours and $248,133, respectively.

  SEQ CHAPTER \h \r 1 	6(d)	Estimating Agency Burden and Costs

  SEQ CHAPTER \h \r 1 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 $58 for managerial staff, $43 for technical
staff, and $20 for clerical staff.  The Agency expects most activities
to be performed by managerial staff (25 percent) and technical staff (75
percent).  

Exhibit 6.2.  Agency Burden/Cost 

Activities	Hours per Labor Category	Labor Cost per Hour	Total Cost per
Activity	Total Hours and Cost

SDSI application form	EPA managerial	EPA technical	EPA managerial	EPA
technical	EPA managerial	EPA technical	Total Hours per Activity	Total
Cost per Activity

Distribute forms	7	23	$58	$43	$406	$989	30	$1,395

Answer questions	7	23	$58	$43	$406	$989	30	$1,395

Record / enter forms	10	30	$58	$43	$580	$1,290	40	$1,870

Verify information; Make awards selection	12	38	$58	$43	$696	$1,634	50
$2,330

Notify applicants of decision	3	9	$58	$43	$174	$387	12	$561

Total 	42	123	--	--	$2,262	$5,289	162	$7,551

  SEQ CHAPTER \h \r 1 	6(e)	Bottom Line Burden Hours and Cost Tables

a.	Respondent Tally

Exhibit 6.3.  Average Estimated Respondent Burden and Cost Summary

Average # of Respondents	Average Burden Hours	Average Cost

375	3,750	$182,625



b.	Agency Tally

								

Exhibit 6.4.  Average Estimated Agency Burden and Cost Summary

Burden Hours	Annual Cost

162	$7,551



	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
at 10 hours per response, including time for reviewing instructions,
gathering information, and completing and reviewing the application. 
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.
EPA-HQ-OPPT-2007-0274, which is available for public viewing at the EPA
Docket Center (EPA/DC), EPA West, Room 3334, 1301 Constitution Ave., NW,
Washington, DC.  The EPA Docket Center Public Reading Room is open from
8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays.
 The telephone number for the Reading Room is (202) 566-1744, and the
telephone number for the Pollution Prevention and Toxics Docket is (202)
566-0280.  An electronic version of the public docket is available at  
HYPERLINK "http://www.regulations.gov/fdmspublic/component/main" 
http://www.regulations.gov/fdmspublic/component/main .  Use this website
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 Officer for EPA.  Please include
the EPA Docket ID No. EPA-HQ-OPPT-2007-0274 in any correspondence.

  SEQ CHAPTER \h \r 1 ATTACHMENTS:

  SEQ CHAPTER \h \r 1 [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     HYPERLINK
"http://www.epa.gov/edocket"  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:
EPA-HQ-OPPT-2006-0343.  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 A – Pollution Prevention Act Section 6604(b)(5); 42 U.S.C.
13103(b)(5)  [The electronic copy is available as part of the electronic
copy of the ICR’s Supporting Statement.]

Attachment B – SDSI Application Form

  SEQ CHAPTER \h \r 1 ATTACHMENT A

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.]

SEC. 6604. EPA ACTIVITIES.

(a) AUTHORITIES.—The Administrator shall establish in the Agency an
office to carry out the functions of the Administrator

under this subtitle. The office shall be independent of the Agency’s
single-medium program offices but shall have the authority to review and
advise such offices on their activities to promote a multimedia approach
to source reduction. The office shall be under the direction of such
officer of the Agency as the Administrator shall designate.

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

(1) establish standard methods of measurement of source reduction;

(2) ensure that the Agency considers the effect of its existing and
proposed programs on source reduction efforts and shall review
regulations of the Agency prior and subsequent to their proposal to
determine their effect on source reduction;

(3) coordinate source reduction activities in each Agency Office and
coordinate with appropriate offices to promote source reduction
practices in other Federal agencies, and generic research and
development on techniques and processes which have broad applicability; 

(4) develop improved methods of coordinating, streamlining and assuring
public access to data collected under Federal environmental statutes;

(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 subtitle 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;

(6) identify, where appropriate, measurable goals which reflect the
policy of this subtitle, the tasks necessary to achieve the goals, dates
at which the principal tasks are to be accomplished, required resources,
organizational responsibilities, and the means by which progress in
meeting the goals will be measured;

(8) 1 establish an advisory panel of technical experts comprised of
representatives from industry, the States, and public interest groups,
to advise the Administrator on ways to improve collection and
dissemination of data;

(9) establish a training program on source reduction opportunities,
including workshops and guidance documents, for State and Federal permit
issuance, enforcement, and inspection officials working within all
agency program

(10) identify and make recommendations to Congress to eliminate barriers
to source reduction including the use of incentives and disincentives;

(11) identify opportunities to use Federal procurement to encourage
source reduction;

(12) develop, test and disseminate model source reduction auditing
procedures designed to highlight source reduction opportunities; and

(13) establish an annual award program to recognize a company or
companies which operate outstanding or innovative source reduction
programs.



ATTACHMENT B

Safer Detergents Stewardship Initiative (SDSI) Application Form

Safer Detergents Stewardship Initiative (SDSI) Application

Overview:

EPA developed the Safer Detergents Stewardship Initiative (SDSI) to
recognize environmental leaders who voluntarily commit to the use of
safer surfactants.  Leading product manufacturers have made great
progress in developing safer, highly effective cleaners.  These
manufacturers believe that producing the safest products possible is
important to their role as stewards of the environment and public
health.  A number of U.S. corporations have acted in advance of SDSI to
use safer surfactants in their entire product lines.  Stakeholders who
have reformulated detergents using safer surfactants have called the
change cost-neutral.  More information on stakeholder views on SDSI can
be found at http://www.regulations.gov, document number:
EPA-HQ-OPPT-2006-0343-0002, docket number: EPA-HQ-OPPT-2006-0343.

What is a Safer Surfactant?:

Safer surfactants are surfactants that break down quickly to
non-polluting compounds. CleanGredients( is a resource for information
on safer surfactants (www.cleangredients.org).

General Requirements:

Candidates should complete this application and have it signed by a
company authority (e.g., CEO or vice president for health and
environment).

Candidates should post a statement on their website describing the
actions that qualify them for recognition under SDSI.  

Categories of Recognition:

There are two categories for recognition under SDSI: Champion and
Partner. 

Champion is the highest level of recognition offered under SDSI.  At
this level, the participant is invited to the SDSI Awards ceremony,
listed on the EPA SDSI website as a champion, and may use a special logo
in their literature to help explain their participation in the program.

The Partner category provides recognition of significant accomplishment
towards the use of safer surfactants.  Partners will be listed on the
EPA SDSI website and may be granted recognition as a Champion in the
future, if appropriate. Partner recognition will sunset on the
commitment date provided in Section 3 of the Application.

Both Champions and Partners will receive a certificate of recognition
from DfE.  To be eligible for the awards ceremony, which will be held in
the Summer of 2008, candidates for Champion status should submit their
application by December 31, 2007.  

Application Process:

Complete the application and submit a signed copy to the SDSI Awards
Coordinator. Unless you claim information as confidential, all
applications received will be considered public information and no
materials submitted will be returned.

Send completed applications to the appropriate address below. Please
note that irradiation of federal mail may damage electronic media or
other materials. It is highly recommended that a package delivery
service be used, especially if you are sending a disk.  

Via US Postal Service: 

US Environmental Protection Agency

Mail Code 7406M 

Safer Detergent Stewardship Initiative 

Attn: DfE Contact

1200 Pennsylvania Ave., NW 

Washington, DC 20460 

Via Package Delivery Service:

Safer Detergent Stewardship Initiative 

Attn: DfE Contact

US Environmental Protection Agency

EPA East, Room 5326

1201 Constitution Ave., NW 

Washington, DC 20004

Phone: 202-564-9910

Confirmation of Receipt: EPA will confirm receipt of applications,
usually by email. If you have not received an acknowledgment within two
weeks of sending your applications, please contact DfE Contact at
contact.dfe@epa.gov or 202-564-9910

Notification:  Winners will be notified prior to the official public
announcement.  Awards will be presented to the primary sponsor of the
application.   

Questions: Questions about eligibility, nomination procedures, or the
Safer Detergent Stewardship Initiative should be directed to DfE Contact
of EPA’s Design for the Environment Program at contact.dfe@epa.gov or
202-564-9910

SECTION 1:  CONTACT INFORMATION

Organization Name:
_________________________________________________________

Contact Name:
______________________________________________________________

Address (City, State, Zip):
____________________________________________________

Phone:
______________________________________________________________________

Fax:
________________________________________________________________________
_

E-mail:
______________________________________________________________________

Website:
_____________________________________________________________________

Award and Type of Organization:

Indicate the type of your organization

______  Chemical Manufacturer – Manufactures surfactants

______  Formulator – Purchases and blends chemicals (including
surfactants) to create an end-use product for retailers and/or
distributors

______  Retailer / Distributor – Sells products containing surfactants

______  Institutional Purchaser – Purchases or specifies cleaning
products for use in multiple facilities (e.g., janitorial service
provider)

______  Other – Influences use of surfactants (e.g., non-profit, trade
association, academia)



Indicate the level of recognition for which you are applying.  

(Refer to Table 1 for a description of Champion and Partner status for
each organization type.)

______ Champion (go to Section 2)	______ Partner (go to Section 3)

Participant Type	Table 1:  Requirements for Achieving:

	Champion Status	Partner Status

Chemical Manufacturers	Demonstrate that you only manufacture safer
surfactants

Document a strategy for ensuring that you manufacture only safer
surfactants	Commit to producing only safer surfactants1 by a date that
is reasonable for your circumstances

Document a strategy for ensuring that you will manufacture only safer
surfactants



Formulators	Demonstrate that you only use safer surfactants in
products1,,

Document a strategy for ensuring that only safer surfactants are used in
products	Commit to using only safer surfactants in your products1,3 by a
date that is reasonable for your circumstances

Document a strategy for ensuring that only safer surfactants will be
used in products



Retailers / Distributors	Demonstrate that only safer surfactants are
included in products2,3 intended for sale

Document a strategy for ensuring that only safer surfactants are
included in products3 intended for sale	Commit to sell only products3
containing safer surfactants by a date that is reasonable for your
circumstances 

Document your active encouragement of the use of safer surfactants



Institutional Purchasers	Demonstrate that you only purchase products
containing safer surfactants

Document a strategy for ensuring that purchased products only contain
safer surfactants	Commit to only use products3 that only contain safer
surfactants by a date that is reasonable for your circumstances

Document your active encouragement of the use of safer surfactants

Others (e.g., non-profits, unions, academia)	Demonstrate outstanding
efforts to encourage the use of safer surfactants	Document your active
encouragement of the use of safer surfactants

SECTION 2: CHAMPION

Fill out this section if you are applying for recognition as a Champion.


Use the space below to explain how you meet the following requirements.

Please include supporting documents when appropriate and note these
documents in your statement. You may attach extra sheets as needed.

If you are a…	You must show that …	And then go to…

Chemical Manufacturer	You only manufacture safer surfactants	Section 2.1

Formulator	You only use safer surfactants in products	Section 2.1

Retailer / Distributor	Only safer surfactants are included in products
intended for sale	Section 2.2

Institutional Purchasers	All the products you purchase contain only
safer surfactants	Section 2.2

Other	You have made outstanding efforts to encourage the use of safer
surfactants	Go to Section 4



________________________________________________________________________
____

________________________________________________________________________
____

________________________________________________________________________
____

________________________________________________________________________
____

________________________________________________________________________
____

________________________________________________________________________
____

________________________________________________________________________
____

________________________________________________________________________
____

List your website describing the actions that qualify the company or
organization for recognition under SDSI.

________________________________________________________________________
____

2.1	Chemical Manufacturers and Formulators only:

Indicate or describe your product stewardship strategy for ensuring the
manufacture or use of safer surfactants:

( Use CleanGredients to choose surfactants

( Other, please describe: 

________________________________________________________________________
____

________________________________________________________________________
____

________________________________________________________________________
____

________________________________________________________________________
____

2.2	Retailers / Distributors and Institutional Purchasers only: 

Document your strategy for ensuring that all of your purchased products
contain only safer surfactants. You may attach extra sheets as needed. 
An example of a strategy is a letter that is sent to suppliers requiring
them to provide products with only safer surfactants.  The retailer /
distributor will not be eligible for Champion recognition until it sells
products with only safer surfactants.

If you are a…	Document a strategy for ensuring that…

Retailer / Distributor	Only safer surfactants are included in products
intended for sale

Institutional Purchaser	Purchased products contain only safer
surfactants



________________________________________________________________________
____

________________________________________________________________________
____

________________________________________________________________________
____

________________________________________________________________________
____

________________________________________________________________________
____

________________________________________________________________________
____

________________________________________________________________________
____

________________________________________________________________________
____

________________________________________________________________________
____

________________________________________________________________________
____

________________________________________________________________________
____

SECTION 3: PARTNERS

Fill out this section if you are applying for recognition as a Partner. 

List your website describing the actions that qualify you for
recognition under SDSI.

________________________________________________________________________
____

Use the space below to describe how you meet the following requirements.
 You should describe your commitment to a complete transition to safer
surfactants by a date that is reasonable for your circumstances. Please
state this date explicitly and explain briefly why it is a reasonable
date for your circumstances. Include supporting materials when
appropriate and note these materials in your statement. You may attach
extra sheets as needed.

If you are a…	You need to document your commitment to…

Chemical Manufacturer	Produce only safer surfactants

Formulator	Use only safer surfactants in your products

Retailer / Distributor	Only sell products that only contain safer
surfactants

Institutional Purchasers	Only purchase products that only contain safer
surfactants

Other	Skip this item



________________________________________________________________________
____

________________________________________________________________________
____

________________________________________________________________________
____

________________________________________________________________________
____

________________________________________________________________________
____

If you are an…	Document the following:

Other (e.g., trade association, NGO, etc.)	Your active encouragement of
safer surfactants



________________________________________________________________________
____

________________________________________________________________________
____

________________________________________________________________________
____

________________________________________________________________________
____

Section 4: CERTIFICATION OF APPLICATION

Please have company authority (e.g., CEO or vice president for health
and environment) sign here to verify the accuracy of the application’s
content.

____________________________________________________

Signature of Authorizing Entity

____________________________________________________

Printed Name and Title

____________________________________________________

Date of Signature

The public reporting and recordkeeping burden for this collection of
information is estimated to average 10 hours per response, including the
time for reviewing instructions, gathering information, and completing
and reviewing the application.  Send comments on the Agency's need for
this information, the accuracy of the provided burden estimates, and any
suggested methods for minimizing respondent burden, including through
the use of automated collection techniques to the Director, Collection
Strategies Division, U.S. Environmental Protection Agency (2822T), 1200
Pennsylvania Ave., NW, Washington, D.C. 20460.  Include the OMB control
number in any correspondence.  Do not send the completed application to
this address.

OMB Control No. 2070-TBD

Approval expires XX/XX/XX   

  ISSA is a leading international trade association for the cleaning
industry.  It has more than 4800 members, including approximately 300
cleaning product manufacturers.

 The Inventory Update Rule (IUR) requires companies that manufacture,
import or use certain chemicals listed on the TSCA inventory to report
to EPA information about these chemicals (e.g., production/use volume)
on a periodic basis.  IUR reporting occurs every five years.  Companies
are currently providing information for calendar year 2005.

 “Green to Gold: How Smart Companies Use Environmental Strategy to
Innovate, Create Value, and Build Competitive Advantage;” Daniel Esty
and Andrew Winston; Yale University Press, New Haven, CT; 2006

 NPEs are part of the APE family of chemicals.

 Includes burden of verifying data (about 40 hours), which EPA estimates
will only need to be done for 1 organization in each participant
category.  This burden, when distributed among all participants, is
about 32 minutes per participant ((40 hrs x 5 participants) / 375 total
participants).

 This includes all companies in the interest list as of December 2006,
excluding EPA and EPA contractors, and counting similar entities such as
“The Dow Chemical Company” and “The Dow Chemical Company, Larkin
Labs” as one company.

 Based on the list of interested parties as of December 2006. 

 These three labor rates were estimated using the following GS-levels:
GS-13 Step-5 for managerial staff, GS-10 Step-10 for technical staff,
and GS-5 Step-1 for clerical staff. 

 An example of a class of safer surfactants is linear alcohol
ethoxylates (LAE). LAEs are toxic to aquatic life, but break down
quickly to non-polluting compounds.  Nonylphenol ethoxylates, commonly
referred to as NPEs, are a surfactant class that does not meet the
definition of a safer surfactant.  Both NPEs and their breakdown
products, such as nonylphenol, are toxic to aquatic life.

 EPA will reserve the right to request, on a confidential basis, the
list of ingredients (e.g., bills of lading, invoices) or other relevant
documentation at any time to confirm that candidates have the achieved
the criteria for recognition.  If documentation is requested but not
received, EPA will withdraw recognition from that candidate. 

 CleanGredients™ is a resource for information on safer surfactants.

 The deadline for using only safer surfactants in third-party finished
goods and Federal Insecticide, Fungicide, and Rodenticide Act
(FIFRA)-registered products is December 31, 2008.

 Products include those whose use routinely results in their discharge
to the environment (e.g., all-purpose cleaners, laundry detergents,
pesticides, airplane de-icers, fire-fighting foams and gels).

 An example of a strategy is a letter that is sent to suppliers
requiring them to provide products with only safer surfactants. The
retailer/distributor will not be eligible for Champion recognition until
its sells products with only safer surfactants.

S

[

Ž

º

[

ƒ

Ê

é

í

h

h

h

h

h

h

 h

h

h

h

 h

 h

 h

h

h

h

 h

 h

㐀ۖĀ̊d搃昀Ĵ

㐀ۖĀ̊d搃昀Ĵ

R

혈0ﰂ⤀䠌$分

혈0ﰂ⤀䠌$分

ô

ô

혈0⠋#

혈0⠋#

혈0⠋#

혈0⠋#

hì

혈0⠋#

ô

ô

혈0⠋#

that Partner recognition will sunset on the commitment date. After this
date, companies will need to apply for Champion recognition.

Information Collection Request for SDSI Program	              	         
             PAGE  25 

