  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:	Safer Detergent Stewardship Initiative (SDSI) Program

		EPA ICR No.: 2261.01	OMB Control No.: 2070-TBD

1(b)	Short Characterization

This new information collection request (ICR) addresses the submission
of applications to EPA for recognition under the Safer Detergent
Stewardship Initiative (SDSI) Program.  EPA announced the program as
part of a Federal Register notice (71 FR 9337; February 23, 2006) that
announced the availability of the Final Aquatic Life Ambient Water
Quality Criteria for Nonylphenol.  Nonylphenol ethoxylates (NPEs) and
their breakdown products, such as nonylphenol, are toxic to aquatic
life.  SDSI 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.

  Under SDSI, EPA will recognize environmental leaders who voluntarily
commit to the use of safer surfactants.  Safer surfactants are
surfactants that break down quickly to non-polluting compounds. 
Surfactants are used in a wide variety of applications and products. 
Examples include detergents, cleaners, airplane deicers, and
fire-fighting foams.  SDSI is designed to 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.

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 an 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.

Candidates should post a statement on their Web site describing the
actions that qualify them for recognition under SDSI.  Candidates should
also complete an application that describes the actions taken to qualify
for recognition and have it signed by a company authority (e.g., Chief
Executive Officer, or vice president with responsibility for product
formulation).

  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 Section 6604 of the Pollution Prevention
Act (PPA) (42 U.S.C. 13103; see Attachment A).  Section 6604(b)(5) of
the PPA directs EPA to facilitate the adoption of source-reduction
techniques by businesses.  Also, 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.  EPA
developed SDSI in recognition of these directives and through
consultation with a broad range of stakeholders. 

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.  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 (EPA Form 6300-2), 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. 

In addition, 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.  For example, 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 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  	In proposing to renew this ICR, EPA provided a
60-day public notice and comment period that ended on July 9, 2007 (72
FR 26357, May 9, 2007).  In total, 13 comments were submitted to the
docket during the 60-day public notice and comment period.  See
Attachment C to this supporting statement for EPA’s response to the
comments.  The comments are summarized as follows.  

	Necessity of the proposed ICR 

	Nine commenters expressed support of SDSI and the proposed ICR, citing
that SDSI is a critical program in moving industry toward
environmentally preferable detergents and that the ICR is an essential
component of the program.  These comments are consistent with EPA’s
consultations with a number of potential respondents, as referenced in
Section 3(c).

	Two commenters questioned the need for SDSI, stating that (1) SDSI is
redundant of private recognition programs and current preferential
purchasing incentives and that (2) EPA has not demonstrated that the use
of detergents or surfactants poses a risk to human health or the
environment.  As stated in Section 3(a), the scope and reach of SDSI are
distinct from those of other programs.  Moreover, as explained in
Section 1(b), NPEs and their breakdown products, such as nonylphenol,
are toxic to aquatic life.

	Accuracy of the Agency’s estimates of the burden of the proposed ICR

	One commenter stated that EPA has underestimated the burden/cost, both
to potential participants and the Agency, but did not suggest
alternative assumptions.  Based on its consultations with potential
respondents, its experience with similar programs, and a lack of
alternative assumptions, EPA believes that the burden and cost estimates
are reasonable and has not made changes to the estimates in Section 6.  

	Quality, utility, and clarity of the information to be collected

	One commenter recommended that the scope of SDSI be modified to exclude
registered pesticides, or allow an additional one-year period for
pesticide products to transition to safer surfactants.  As detailed in
the application package, EPA is allowing formulators of pesticide
products an extra year to incorporate only safer surfactants in
third-party finished goods and Federal Insecticide, Fungicide, and
Rodenticide Act (FIFRA)-registered products.  In addition, one commenter
recommended that EPA provide a better definition for the term “safer
detergent” since it may be unclear what constitutes an unsafe
detergent. Based on our consultations, EPA believes that the current
definition is clear that NPEs are not allowed for recognition under
SDSI.  Also, resources, including CleanGredients, are available to aid
companies as they continuously improve the ingredients in all their
products.  Another commenter suggested several editorial changes to the
application package which EPA agreed with and incorporated.

	Ways to minimize the burden on potential respondents 

As stated above, several editorial changes to the application package
were recommended to make it clearer and easier to submit; EPA
incorporated these changes.  In addition, one commenter recommended that
EPA accept electronic submissions to increase efficiency and reduce
paper use.  In response to this comment and to minimize the paper use,
EPA will accept electronic copies of the application that include a
scanned signature.

  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. 
Senior managers from EPA’s Office of Science and Technology (Office of
Water) and Office of Pollution Prevention and Toxics 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.  Stakeholders
who spoke to express support for the program at the public meeting
include:

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.  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.

	In addition to these stakeholder consultation and outreach efforts,
under, OMB regulations require agencies to consult with potential ICR
respondents and data users about specific aspects of ICRs (5 CFR
1320.8(d)(1)).  In accordance with this regulation, EPA consulted with
six potential respondents by telephone to get feedback on the following
questions:  

Please provide your best estimate regarding how long it would take to
complete the application in terms of total hours. 

We are also interested in how many personnel (i.e., clerical, technical,
and managerial) it would take for applicants to review the program
information, obtain approval from senior management and complete the
form. 

In addition, please provide us with any constructive criticism /
comments you might have regarding the application itself, questions
posed, instructions, description of the program, etc.  Please note that
the SDSI program has changed somewhat.  When we first discussed SDSI it
was focused exclusively on NPEs.  Now the program is more generally
focused on encouraging companies to move towards "safer surfactants." 
We would greatly appreciate your comments on this change in focus also.

	EPA received direct feedback from the following individuals; a few of
these individuals also provided input through the public comment
process.  

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

Cory Hammock, Clean Control, 478-922-5340

Roger McFadden, Coastwide Laboratories, 503-218-4900

Lauren Heine, Lauren Heine Group LLC, and Green Blue Institute,
360-738-4643

John Bartlett, Barricade International, 800-201-3927

Robert Israel, JohnsonDiversey, 262-631-4437 

	Bill Balek -- a representative from ISSA (a trade association for the
cleaning industry) -- independently solicited feedback from the
following members of ISSA and forwarded it to EPA.  

Candice Rushton, Betco, 419-725-3833

Carol Chapin, Simple Green, 562-795-6000

Barbara Whitstone, CleanPower, 414-302-3000

John Barrett, KIMCO Corporation, 708-583-9800

Jon Scoles, Scoles Floorshine Industries, 732-681-4545

Linda Silverman, Maintex, 626-961-1988

	See Attachment D for a summary of all the responses received through
the consultations.  In general, the individuals were supportive of the
ICR and said the burden estimates appeared reasonable.  Therefore, EPA
made no changes to the burden estimates 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 (EPA Form 6300-2)
(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 should post a statement on their Web site describing the
actions that qualify them for recognition under SDSI.  In addition,
candidates conduct the following activities in order to complete and
submit the SDSI Application Form (EPA Form 6300-2):

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.

EPA will also evaluate whether there is a correlation between SDSI
participation and environmental outcomes by using Inventory Update Rule
data 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.

  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.

  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 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.

The data collection mechanism for SDSI is the SDSI Application Form (EPA
Form 6300-2).  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.  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 and include posting relevant information on the applicant
website.  

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 5 hours (4 technical, 1 clerical) and posting
information on company websites will take 1 hour (1 technical) given the
data reporting requirements.  Included in the application form estimate
of 5 hours is the potential burden that would be incurred if EPA finds
it necessary to verify the information in the application.  For 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.

  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	4	1	0	148	37	185	$64	$53	$26	$8,806

	Post information on website

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

	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 package6

0	4	1	0	824	206	1030	$64	$53	$26	$49,028

	Post information on website

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

	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 package6

0	4	1	0	92	23	115	$64	$53	$26	$5,474

	Post information on website

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

	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 package6

0	4	1	0	92	23	115	$64	$53	$26	$5,474

	Post information on website

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

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

Private Sector and 

Local Government	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 package6

0	4	1	0	344	86	430	$64	$53	$26	$20,468

	Post information on website

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

	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, 1407 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
companies8 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 $589 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	Mgmt	Tech.	Mgmt	Tech.	Mgmt	Tech.	Hours per
Activity	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.

The Agency has established a public docket for this ICR under Docket ID
No. EPA-HQ-OPPT-2007-0274, which is available for online viewing at
www.regulations.gov, or in person 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.    You may submit comments regarding 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.

Submit your comments, referencing Docket ID No. EPA-HQ-OPPT-2007-0274
and OMB Control No. 2070-NEW, to (1) EPA online using
www.regulations.gov (our preferred method), or by mail to: Document
Control Office (DCO), Office of Pollution Prevention and Toxics (OPPT),
Environmental Protection Agency, Mail Code: 7407T, 1200 Pennsylvania
Ave., NW,  Washington, D.C. 20460, and (2) OMB by mail to: Office of
Information and Regulatory Affairs, Office of Management and Budget
(OMB), Attention: Desk Officer for EPA, 725 17th Street, NW, Washington,
DC 20503.

ATTACHMENTS TO THE SUPPORTING STATEMENT

Attachments to the supporting statement are available in the public
docket established for this ICR under docket identification number
EPA-HQ-OPPT-2007-0274.  These attachments are available for online
viewing at www.regulations.gov or otherwise accessed as described in
section 6(f) of the supporting statement.

  SEQ CHAPTER \h \r 1 

Attachment A:	42 USC 13103 - Pollution Prevention Act Section 6604. Also
available at online at the US House of Representatives’ Office of the
Law Revision Counsel’s   HYPERLINK
"http://uscode.house.gov/uscode-cgi/fastweb.exe?getdoc+uscview+t41t42+75
17+0++%28%29%20%20AND%20%28%2842%29%20ADJ%20USC%29%3ACITE%20AND%20%28USC
%20w%2F10%20%2813103%29%29%3ACITE%20%20%20%20%20%20%20%20%20"  US Code
website 



Attachment B:	EPA Form 6300-2 - SDSI Application Form



Attachment C:	Response to Public Comments



Attachment D:	Summary of Consultations with Potential Respondents



OMB Control Number 2070-NEW; EPA ICR Number 2261.01

ICR ATTACHMENT A

Pollution Prevention Act Section 6604

42 U.S.C. 13103

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.

OMB Control Number 2070-NEW; EPA ICR Number 2261.01

ICR ATTACHMENT B

Safer Detergents 

Stewardship Initiative

Instructions for Application Form

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.

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

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.

EPA reserves the right to request at any time, on a confidential basis,
appropriate documentation (including but not limited to bills of lading,
invoices, material safety data sheets, and list of ingredients) to
confirm that candidates have achieved the appropriate criteria for
recognition.  If documentation is requested but not received within a
reasonable time, EPA may deny or withdraw recognition from that
candidate.

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.

Guidelines for achieving Champion or Partner Status are provided in
Table 1. 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 2008, candidates for Champion status should submit
their application by the date provided on the DfE website
(http://www.epa.gov/dfe/pubs/projects/formulat/sdsi.htm). 

Application Process: The application will be available online and may be
filled out and submitted in hard copy or electronically to SDSI@epa.gov.
Unless you claim information as confidential, all applications received
will be considered public information and no materials submitted will be
returned. For security purposes, confidential information may not be
submitted electronically.  If you choose to send the application
electronically, the signed signature page must be scanned in and
reattached to the electronic application.

If you choose to submit a hard copy application, send your completed
application 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.   

Submit this form to the following address:

US Environmental Protection Agency

Safer Detergent Stewardship Initiative (7406M)

Attn: DfE 

Via regular/certified mail: 

1200 Pennsylvania Ave., NW 

Washington, DC 20460 

Via overnight mail:

1201 Constitution Ave., NW 

EPA East, Room 5326

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

Paperwork Reduction Act Notice 

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, posting
information to the internet, and reviewing and completing the
application.  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.

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.



Participant Type	Table 1:  Guidelines 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 1a:

Enter requested information for the authorized representative

	Organization Name

	Contact Name

	Address

	Address

	Phone	Fax

	Email

	Website



	SECTION 1b:

Indicate your type of 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)





SECTION 1c:  

Indicate the level of recognition for which you are applying (refer to
the instructions for a description of Champion and Partner status for
each organization type)



Champion (go to Section 2)



Partner (go to Section 3)











                                             Safer Detergents
Stewardship Initiative       	                  Page 2 of 5

SECTION 2:

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

	If you are a…	Demonstrate in SECTION 2a that…	And the go to…

	Chemical Manufacturer	You only manufacture safer surfactants	Section 2b

	Formulator	You only use safer surfactants in products	Section 2b

	Retailer / Distributor	Only safer surfactants are included in products
intended for sale	Section 2c

	Institutional Purchasers	All the products you purchase contain only
safer surfactants	Section 2c

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





	SECTION 2a:

Use this space to explain how you meet the above requirements.

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

	_________________________________________________________________

_________________________________________________________________

_________________________________________________________________

_________________________________________________________________

_________________________________________________________________

_________________________________________________________________

_________________________________________________________________

_________________________________________________________________

_________________________________________________________________

_________________________________________________________________

_________________________________________________________________





SECTION 2b (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

Provide the URL for that section of your website describing the actions
that qualify the company or organization for recognition under SDSI:

_________________________________________________________________

	( Other, please describe:

________________________________________________________________________
________________________________________________________________________
________________________________________________________________________
________________________________________________________________________
_____________________________________



                                             Safer Detergents
Stewardship Initiative       	                  Page 3 of 5

SECTION 2c (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.*
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



* An example of a strategy would be the establishment of a policy that
requires suppliers to provide products that contain only safer
surfactants. This strategy may be evidenced by a letter that is sent to
suppliers requiring them to provide products with only safer
surfactants, or a comparable statement posted on a company’s website. 
The retailer / distributor will not be eligible for Champion recognition
until it sells products with only safer surfactants.

                                             Safer Detergents
Stewardship Initiative       	                  Page 4 of 5

SECTION 3:

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

	If you are a…	Document in SECTION 3a 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

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





SECTION 3a:

Use this space to describe how you meet the above requirements.*

	_________________________________________________________________

_________________________________________________________________

_________________________________________________________________

_________________________________________________________________

_________________________________________________________________

_________________________________________________________________

_________________________________________________________________

_________________________________________________________________

	

Provide the URL for that section of your website describing the actions
that qualify you for recognition under SDSI:

_________________________________________________________________



* 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.

                                        Safer Detergents Stewardship
Initiative       	                 Page 5 of 5

SECTION 4:

Certification of Application	Please have the appropriate company
authority (e.g., CEO, vice president for health and environment,
division head, or other authorized signatory) sign here to verify the
accuracy of the application’s content.





Signature of Authorizing Entity	Date

Printed Name and Title	Date



I hereby affirm that the contents of this application are true and
accurate to the best of my knowledge, and that I am an authorized
representative of the company or organization named above and am duly
authorized to sign this application.

OMB Control Number 2070-NEW; EPA ICR Number 2261.01

ICR ATTACHMENT C

Response to Public Comments

MEMORANDUM

SUBJECT:	Response to Comments for DfE’s Safer Detergents Stewardship
Initiative (SDSI) Information Collection Request 

FROM:	Neil Patel, Acting Division Director,

Economics Exposure and Technology Division 

			

TO:		Angela Hofmann, Director, 

Regulatory Coordination Staff

DATE:		August 2, 2007

The Federal Register Notice for the ICR “Safer Detergent Stewardship
Initiative (SDSI) Program” (docket identification number
EPA-HQ-OPPT-2007-0274) was published on May 9, 2007.  In total, 13
commenters provided feedback during the 60-day public notice and comment
period.  Below is a brief summary of the comments made and our responses
to them. 

Necessity of the proposed ICR 

Nine commenters expressed support of SDSI and the proposed ICR, citing
that SDSI is a critical program in moving industry toward
environmentally preferable detergents and that the ICR is an essential
component of the program.  These comments are consistent with EPA’s
consultations with a number of potential respondents.

Two commenters questioned the need for SDSI, stating that (1) SDSI is
redundant of private recognition programs and current preferential
purchasing incentives and that (2) EPA has not demonstrated that the use
of detergents or surfactants poses a risk to human health or the
environment.  As explained in the ICR supporting statement, the scope
and reach of SDSI are distinct from those of other programs.  Moreover,
NPEs and their breakdown products, such as nonylphenol, are toxic to
aquatic life.  

Accuracy of the Agency’s estimates of the burden of the proposed ICR

One commenter stated that EPA has underestimated the burden/cost, both
to potential participants and the Agency, but he did not suggest
alternative assumptions.  Based on its consultations with potential
respondents, its experience with similar programs, and a lack of
alternative assumptions, EPA believes that the burden and cost estimates
are reasonable and has not changed the estimates.  

Quality, utility, and clarity of the information to be collected

One commenter recommended that the scope of SDSI be modified to exclude
registered pesticides, or allow an additional one-year period for
pesticide products to transition to safer surfactants.  As detailed in
the application package, EPA is allowing formulators of pesticide
products an extra year (i.e., a deadline of December 31, 2008) to
incorporate only safer surfactants in third-party finished goods and
Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA)-registered
products.  In addition, one commenter recommended that EPA provide a
better definition for the term “safer detergent” since it may be
unclear what constitutes an unsafe detergent. Based on our
consultations, EPA believes that the current definition is clear that
NPEs are not allowed for recognition under SDSI.  Also, resources,
including CleanGredients, are available to aid companies as they
continuously improve the ingredients in all their products.  Another
commenter suggested several editorial changes to the application package
which EPA agreed with and incorporated.

Ways to minimize the burden on potential respondents 

As stated above, several editorial changes to the application package
were recommended to make it clearer and easier to submit; EPA
incorporated these changes.  In addition, one commenter recommended that
EPA accept electronic submissions to increase efficiency and reduce
paper use.  In response to this comment and to minimize the paper use,
EPA will accept electronic copies of the application that include a
scanned signature.

OMB Control Number 2070-NEW; EPA ICR Number 2261.01

ICR ATTACHMENT D

                            Summary of Consultations with Potential
Respondents

Company:	Betco (Formulator; $50 to $100 Million)

Address:	1001 Brown Avenue, Toledo, Ohio 43607

	Contact:  	Candice Rushton;	Phone: 419-725-3833; email: 
crushton@betco.com

We have the following comments concerning the SDSI Program application. 

(1) Our best estimate of hours required to complete the application
including running formula queries and production figures required to be
submitted with the application is estimated to be approximately 4 hours.
This would apply under either Champion or Partner status. 

a. The background for planning a strategy for estimating time frames for
phase out of existing surfactants into safer surfactants is estimated at
approx. 40 hours. 

b. NOTE: This does not include any actual reformulation work or testing
as ISSA has requested that comments focus on the application. 

(2)  The application would require 1 regulatory contact, at least 1
chemist, and senior management. 3 people total in order to complete the
application. 

(3) Overall the application is clear and easy to follow.  

a. Comments concerning submission of surfactant volume use.  

i.  It is indicated that these items can be submitted as “trade secret
information”.   

1. As many of the surfactants that will be in use will be common in the
market place, therefore, not necessarily qualifying as “trade
secret” status, would it be more appropriate to indicate that volumes
could be submitted as “Confidential Business Information” (CBI)?  

b. The application indicates that EPA will reserve the right to request
on a “confidential basis” the list of ingredients. 

1.  Formulators and manufacturers should be provided the opportunity to
be able to submit to EPA additional information that may be relevant to
phase out strategy or similar as CBI during initial application and
during formal recognition status, with justification why such
information should be submitted as CBI. 

a. EPA would have the opportunity to grant or deny the justification for
CBI.  

(4) At current, there does not appear to be a charge for application
submission itself. 

b. Is there the potential that a charge would be applied to any
participant type or status in the future?  

c. If so, the application fee should be clearly indicated on the
application. 

(5) Concerning Certification of Application. “Company Authority”
currently 

indicates (CEO or Vice President). 

d. Could this be expanded to include “or other authorized
signatory”? 

i. 	In the case of formulators and manufacturers, Technical Directors
and/or Regulatory Managers usually have this authority within their
respective firms. 

We appreciate the opportunity to comment on the SDSI application. We
look forward to working with ISSA in the future on this endeavor. 

Company:  	CleanControl (Formulator $20 to $50 Million)

Address:  	PO Box 7444, Warner Robins, GA, 31095

	Contact:  	Cory Hammock; Phone:  478-922-5340; email:
cory.hammock@cccga.com

We appreciate the opportunity to respond to your request to review the
draft application for the Safer Detergents Stewardship Initiative (SDSI)
from the U.S. EPA Design for the Environment (DfE). 

As you as aware, our company has worked since our incorporation in 1991
to improve the environmental profiles of our cleaning formulations. In
December 2005, we completed a 100% phase-out of Alkylphenol Ethoxylate
(APE). During this final phase out period I became aware of SDSI.
Initially the program was entirely focused on phasing out APE. Your
invitation to review the program indicates “More information on the
SDSI program can be found at:
http://www.epa.gov/dfe/pubs/projects/formulat/sdsi.htm”. Here SDSI is
defined as follows: 

“What is the Safer Detergents Stewardship Initiative? 

EPA is developing the Safer Detergents Stewardship Initiative (SDSI) to
recognize companies, facilities, and others who voluntarily phase out or
commit to phasing out the manufacture or use of nonylphenol ethoxylate
surfactants, commonly referred to as NPEs. These surfactants are used in
detergents in cleaning and other products. Both nonylphenol ethoxylates
and their breakdown products, such as nonylphenol, can harm aquatic
life. 

The Safer Detergents Initiative will complement EPA's Aquatic Life
Ambient Water Quality Criteria for Nonylphenol. These criteria are
designed to protect aquatic life in both fresh and saltwater and can
form the basis for state and tribal water quality standards. For more
information, see the Aquatic Life Criteria for Nonylphenol. 

The DfE website supports my initial assessment. However, the draft
program goes much further than phasing out APE, to instituting language
that incorporates all “unsafe” surfactants. While this is certainly
admirable and desirable, “unsafe” surfactants are not clearly
defined and therefore the program is less practical.  

CleanGredients defines surfactant as follows: Surfactant refers to any
organic substance and/or preparation which has surface-active properties
and which consists of one or more hydrophilic and one or more
hydrophobic groups of such a nature and size that it is capable of
reducing the surface tension of water, and of forming spreading or
adsorption monolayers at the water-air.

Additional Follow Up Comments:

If the problems I mentioned could be addressed by simply checking
“other in section 2.1” and stating that we only use DfE screened and
recognized linear alcohol ethoxylates in applications where APE was
formally used, I would estimate it would take about.

 

1.  3 hours to document current use levels and reductions of APE through
substitution with safer alternatives (linear alcohol ethoxylate) in the
form of a report generated from our inventory database. Also, we assume
this would be an annual requirement. 2 hours annually thereafter. 

2.  2 hours to complete form and submit. 

3.  4 hours to develop and post statement on website describing actions
that qualify us for recognition.

4.  If necessary, a visit from EPA to inspect site, invoices, etc.
should be take no longer than 4 hours. 

 

I view this as less than significant and well worth the effort to obtain
recognition. 

 

If this is not an alternative, it is highly unlikely that would commit
to the program since it would be impossible to document compliance with
a program that is not clearly defined. 

 

I have discussed this issues many times with the producers of NPE. They
need to submit data to clear NPE or concede. The DDBSA producers seem to
have found away to improve/support its environmental data profile.  As
a formulator, I recognize NPEs positive performance and cost attributes
and would welcome it being cleared of environmental toxicity concerns.
However, after 20 years of continuously increasing scrutiny, I would
assume if they could they would have done so by now.

 

Last Comment:

I should clarify that my focus was not on the time estimates. First, we
have already transitioned from NPEs. Second, we already track chemical
usage for other regulatory production reporting requirements such as
SARA 312, SARA 313, Pesticides, VOCs, etc. Therefore, resources required
for clerical, technical and managerial review would be minimal if the
program was clearly defined. The EPA website and your e-mail imply a
clearly defined program; however, the draft is not. 

3.  	Company:  	Simple Green (Formulator $50 to $100 Million)

	Address:  	15922 Pacific Coast Highway, Huntington Harbor, CA 92649 

	Contact:  	Carol Chapin; Phone:  562-795-6000; email: 
cchapin@simplegreen.com

1.  Please provide your best estimate regarding how long it would take
to complete the application in terms of total hours.  

Answer:  About 8 hours maximum.  3 hours to draft web site statement,
discuss with management and get their approval; 4 hours to gather and
check surfactant data; 1 hour to post commitment statement to our web
site.

2.  We are also interested in how many personnel (i.e., clerical,
technical, and managerial) it would take for applicants to review the
program information, obtain approval from senior management and complete
the form.  

Answer:  For us, the process of calculating surfactant use data and
completion of the form should only take about 4 hours for 1 person, as
we already went through this exercise for our own internal
decision-making purposes.  I think EPA will find that most
manufacturers/formulators of mid- to large size have already taken a
look at this issue.  However, if we were to be starting from scratch, I
would add another 8 hours onto the time given above (total of 16 hours.)
Obtaining approval from senior management wouldn’t take long at all,
but management would insist that submitted data be confidential business
information. 1 person to post statement to web site.

3.  In addition, please provide us with any constructive criticism /
comments you might have regarding the application itself, questions
posed, instructions, description of the program, etc.  

Answer:  This application appears very straight forward in its present
form.

(NOTE:  At this time we are only soliciting feedback on the application
itself and NOT the actual work of transitioning from NPEs to safer
surfactants.) 

4.  Please note that the SDSI program has changed somewhat.  When we
first discussed SDSI it was focused exclusively on NPEs.  Now the
program is more generally focused on encouraging companies to move
towards "safer surfactants".  We would greatly appreciate your comments
on this change in focus also.  

Answer:  I don’t see a problem with the change in focus – and EPA
should also recognize that there are lots of safer surfactants out there
that have not participated in their database.

4.  Formulator $20 to $50 Million

I estimate that it would take a minimum of 200 hours to satisfactorily
complete this application.

Completing the application would require at least one clerical person,
two to three technical people,  & at least one senior manager. Also an
IT person’s time would be required.

Documentation is required but so far as I can see the mechanism for this
documentation is not specifically addressed. ( i.e. how do we prove we
are/will be in compliance?)

The term safer surfactants is too vague. Organizations will not want to
commit to a vague goal like that can be changed or expanded during the
implementation process. DfE needs to pick a  specific category like
NPEs/APEs & address eliminating/reducing those in our industry. 

4.  	Company:	CleanPower (Building Service Contractor, Under $5 Million)

Address:	124 N. 121st Street, Milwaukee, WI 53226

Contact:	Barbara Whitstone; Phone: 414-302-3000; Email: 
whitstone@cleanpower1.com

As an Institutional Purchaser, our time to complete the actual
application would be fairly minimal.  I would estimate no more than
four hours total.

I would complete the form myself, and ask our President of Specialty
Services to review it as chemical purchases also come under his purview.

Reviewing our list of current products (over 200!) to ensure that they
meet the requirements would take much longer.  However, less than 30
products make up over 90% of what we use; the rest are specialty
chemicals for unusual situations.  Also, we could ask our vendors to
help us with this part of the project.  I would estimate this would
take 16 hours of clerical time.

Putting the information on our website would be outsourced, and I am
unable to provide a time or cost estimate for that.

5.  	Company:	KIMCO (Building Service Contractor, $50 to $100 Million)

Address: 	KIMCO Corporation, 7300 W. Montrose Ave., Norridge, IL 60706

Contact:	John Barrett, CEO; Phone:  708-583-9800;  Email:    HYPERLINK
"mailto:jbarrett@kimcocorp.com"  jbarrett@kimcocorp.com 

Question 1        How many hours to complete?  For an
institutional purchaser at a "Partner" level we are estimating 16 hours
work to complete and then 1-2 hours 

per month for tracking, monitoring and audit of
distributors/manufacturers.

 

Question 2        How many personnel?  For KIMCO we are
estimating corporate involvement from 3 people and coordinating field
management involvement of 7 people.

 

Question 3        Feedback and comments from KIMCO.  Provide
better definition for the institutional purchasers between "Champion"
and "Partner" level participation.

(i.e.  Champion "All products you purchase must contain only safer
surfactants, Partner "Only purchase products that only contain safer
surf.....")

These seem to say the same thing.

 

In the footnote, specific classes of products are defined.  They do not
include floor strippers and finishes as well as carpet detergents.  Do
these need to be included as the have an impact on the environment.  

 

6.  	Company:	Scoles Floorshine (Distributor, Under $5 Million)

Address: 	Scoles Floorshine Industries, PO Box 2303; Farmingdale, NJ
07727

Contact:	Jon Scoles; Phone: 732-681-4545; Email:    HYPERLINK
"mailto:jscoles1@aol.com"  jscoles1@aol.com 

1.  Filling out the initial application, at least for a distributor,
seems relatively simple.  Writing letters to all of my chemical
suppliers requesting a list of all non-NPE products would take little
time.

 

2.  Gathering all that information, cross checking these products to
existing products, testing them as to comparable performance and
sampling them out to key customers for their input would take a lot of
time.

 

3.  If these products were found to be unacceptable to the customer
base, new sources of suppliers that meet the EPA requirement would have
to be found and the testing process started over.  

 

4.  Knowing the difficulty of securing certain product lines and also
the years of marketing your company in relation to these lines, it would
be hard to start over without losing a large percentage of your customer
base.  Not to mention dispensing equipment that would have to be
replaced.

 

5.  The cost factor of these products would also have to be considered
as to how much the customer is willing to pay.

 

6.  Knowing how many qualified manufacturers and the range of
products that will be available is essential before even beginning the
application.

     

The leap of faith for the distributor is that enough manufacturers will
buy into this program to make it competitive and the end user is willing
to pay more for new and possibly less effective products.  My concern
is there won't be enough non-NPE products, initially, to fill all the
product demands of our customer base. This in itself would eliminate me
and most distributors from this program. 

 

The bottom line; filling out the application would only take a few hours
with a couple of staff members.  Executing the entire program to
completion would take 1-2 years.

 

7. 	Company:	Maintex (Formulator, $20 to $50 Million)

Address: 	Maintex, 13300 E. Nelson Ave., City of Industry, CA 91744

Contact:	Linda Silverman; Phone:  626-961-1988; email:  Linda@mainex.com

First let me say that we manufacture over 300 formulas and the majority
of those products do contain NPEs.  This EPA initiative would require
the reformulation and testing of all of these items which would take at
least a year to accomplish. 

 

At this time our Green Products represent a very minimal amount of our
actual sales.  We are seeing growth in that area of our business, but
to discontinue the sale of all items that are not green formulated would
drastically affect our business and we would not consider such a
strategy.  We could not be competitive in our marketplace and it could
conceivably result in a complete business failure.  As much as we want
to support Green Business we must also maintain our current sales level
and failing to offer other products would present a huge negative
impact.

 

Filling out the application would not take too much time, but
reformulating and committing to the process is another story entirely.

 

8.  	Company:	Coastwide (Distributor and Formulator; $20 to 50 Million)

Address:	10000 S.W. Commerce Circle Drive, Wilsonville, OR

Contact:	Roger McFadden; Phone:  503-218-4900; email: 
rogermcfadden@centurytel.net

1.  Please provide your best estimate regarding how long it would take
to complete the application in terms of total hours.

FEEDBACK: I would estimate the total time for completing and submitting
the application to be 4 hours for most companies.

2.  We are also interested in how many personnel (i.e., clerical,
technical, and managerial) it would take for applicants to review the
program information, obtain approval from senior management and complete
the form.

FEEDBACK: Environmental manager, qualified chemist or scientist,
clerical person, communication’s manager and senior manager.

3.  In addition, please provide us with any constructive criticism /
comments you might have regarding the application itself, questions
posed, instructions, description of the program, etc.

FEEDBACK: The definition of a safer surfactant is vague. What is the
definition of a “non-polluting compound”? It appears NPEs would not
be classified as safer surfactants because they are “toxic to aquatic
life”. Is “toxic to aquatic life” the same as “non-polluting
compound”? I would think that if a manufacturer of NPEs could
demonstrate that their NPE surfactant was a “non-polluting compound”
that they would be able to meet the criteria as it is currently defined.
I would prefer to see “non-polluting” be replaced with the word
“toxic”.  I would also prefer that the definition include
“readily biodegradable” and “cannot be listed as an endocrine
disrupter”.

ocrine disrupters. CleanGredients is a resource for information on
safer surfactants.”

9.  	Company:	ISSA  (Non-Profit Trade Association)

Address:		ISSA, 7373 N. Lincoln Avenue, Lincolnwood, IL 60712

Contact:		Bill Balek; Phone: 847-982-0800; email: bill@issa.com

1.  Please provide your best estimate regarding how long it would take
to complete the application in terms of total hours.

RESPONSE:  ISSA would apply as a Champion in the “Other” category. 
As such, the application process would be pretty straightforward.  It
would require searching our files to identify and catalog the various
activities in which we have been involved that have encouraged the use
of safer surfactants.  I estimate this process would take approximately
an hour.

Completion of the application itself should take no more than 45 minutes
or so, and we estimate that it would take a total of 3 hours to draft,
approve, and post web statement.

Total time estimated:  4 hours, 45 minutes.

2.  We are also interested in how many personnel (i.e., clerical,
technical, and managerial) it would take for applicants to review the
program information, obtain approval from senior management and complete
the form.

RESPONSE:  I estimate 4 individuals would be involved in the process.  I
(Bill Balek) would be responsible for doing the necessary research /
review of our SDSI related activities, as well as drafting the
application and web content.  Our marketing director would review / edit
the web statement, which would then be submitted for review by our
executive director.  Once approved our IT person would post to the web.

3.  In addition, please provide us with any constructive criticism /
comments you might have regarding the application itself, questions
posed, instructions, description of the program, etc.

RESPONSE:  ISSA recommends that you try to define / identify as best as
possible the surfactants that you would like to have companies
discontinue, as well as those surfactants that you would like companies
to transition to.  While we realize the reasons why DfE has dropped
reference to NPEs, formulators have expressed some level of discomfort
with the program as defined in the application.  Specifically, they have
referenced the use of the term “safer surfactants” as well as the
lack of specific reference to “bad” surfactants.

10.  	Company:	Green Blue Institute

Address:		515 Whitecap Road, Bellingham, WA  98229, 

Contact:		Lauren Heine, Senior Fellow, Green Blue Institute; Principal,
Lauren Heine Group LLC; Phone:  360-738-4643; email:   HYPERLINK
"mailto:Lauren.Heine@GreenBlue.org"  Lauren.Heine@GreenBlue.org 

  

I commend U.S. EPA and the Design for the Environment Program for the
Safer Detergent Stewardship Initiative.

This is an important and valuable program for a number of reasons:

It supports EPA regulatory priorities via a voluntary initiative thus
demonstrating harmonization between programs at EPA.  Often large
organizations are criticized for having uncoordinated “silos” of
activity.  But the SDSI program is synergistic with EPA regulatory
priorities to reduce the levels of nonylphenol in our nation’s rivers,
streams, and other water bodies therefore demonstrating a coordinated
and thoughtful effort by EPA.

It is a voluntary program that provides positive recognition for those
organizations who wish to participate.  It is not mandatory – no one
is required to participate.  But in a day when a growing number of
companies are seeking ways to distinguish themselves as leaders in
environmental and sustainability initiatives, SDSI offers a new and
effective channel for market recognition.  It uses positive market-based
incentives and not regulatory requirements.

The requirements for participating are not burdensome.  For companies or
other organizations that seek to participate, they will need to
demonstrate that they have committed to and/or have effectively ceased
from using NPEs.  It is hardly burdensome to ask a company to
demonstrate that they know what they are actually purchasing and are
using as ingredients in their products!  This is responsible business. 
Irresponsible businesses end up using lead in baby bibs and melamine in
dog food and don’t even know it. The DfE reporting requirement to
demonstrate qualification for SDSI will only make businesses more
informed and responsible.  This is not a burden but rather an
opportunity.

Ecolabels and environmentally preferable products are a growing segment
of the market.   But they are a small segment of the market, and by
definition, ecolabels will only ever be achievable by the top 20% of the
marketplace.  Ecolabelling organizations say that when 20% of the market
can meet their standard that they will update the standard -- otherwise
there would be no distinction for environmentally preferable.  At one
time, I spoke with representatives of one of the largest industrial and
institutional cleaning products manufacturing companies in the US.  They
proudly noted that at the time they had 6 ecolabeled/recognized products
(I believe they are up to ~15 now – two years later).  I commended
them on their achievement and asked how many products they actually
sold.  They said 6000!   Ecolabels and partnership programs such as the
DfE Formulator Program help to ensure the human and environmental health
and safety of key products – but what about the other 5,994?  Greening
chemical products through ecolabeling/product recognition is like
fishing selectively with a fishing pole.  But greening a company’s
full product inventory is like fishing with a fishing net.  Both
approaches yield important results and BOTH should be used.  Labeling
results in a relatively few products that are “best in class” and
that represent leadership in formulation.  SDSI will result in a larger
number of products that do not use NPEs which has been demonstrated to
be hazardous in the environment.  The two approaches are mutually
supporting.  A third approach of course might be to use regulations to
force companies to comply by ceasing to use NPEs altogether, but that
just creates a regulatory burden for companies and for the Agency.  Why
not see if the goal of low levels of NP in US waters can be achieved by
preferred purchasing and voluntary initiatives such as SDSI.

11.	Company:	Barricade International

Contact:		John Bartlett, phone:  800-201-3927

Need/Authority for the Collection

We at Barricade agree and fully support the efforts of EPA’s SDSI. 
The data collection is necessary and appropriate to determine the amount
of NPEs entering our nation’s waters.  It is particularly important in
the case of water enhancing gels used in wildland firefighting where
fire behavior is the primary consideration on when and where to use
these products.  We also believe that the SDSI will lead to use of safer
water enhancing gels that are NPE-Free.

On a similar note, there is a reluctance/inertia on the part of Federal
and State agencies to embrace new and safer chemical technologies in
wildland firefighting.  The fact that there is a Presidential Executive
Order that recognizes the priority to be given more environmentally safe
products does not seem to be an incentive for the Federal use of
NPE-Free products. The incorporation of water enhancing gels used in
firefighting in the SDSI will tend to highlight the importance of safer
products.

Accuracy of Information Collection Burden Estimates

We have reviewed Exhibit 6.1 and concur with the estimate of collection
burden.  We would certainly anticipate the cost and time to be well
within the estimate.

Enhance the Quality, Utility, and Clarity or Information Collected

We have reviewed the information to be collected and find it useful,
necessary and clear.  We do have one suggestion:  Is it possible to
include Federal and State agencies as an “Institutional Purchaser”
on the form?   We can make a safer and more effective product without
NPEs but will it be USED?

Minimize the Burden

We have reviewed the methods, time, and costs involved in responding to
this initiative and believe that the EPA has minimized the burden to the
public and is certainly within the capabilities of small businesses such
as ours.

 “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

  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.

 NPEs are part of the APE family of chemicals.

 The meeting notes are available in the public docket (  HYPERLINK
"http://www.regulations.gov/fdmspublic/component/main?main=DocumentDetai
l&d=EPA-HQ-OPPT-2006-0343-0002"  Docket ID No. EPA-HQ-OPPT-2006-0343 ),
which can be accessed online via   HYPERLINK
"http://www.regulations.gov/"  Regulations.gov 

 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).

7 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.

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

9 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.

 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.

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 Examples of contributions that would qualify include those that have
developed means for surfactant users to identify safer surfactants,
those that have taken action to educate industry or the public about
safer surfactants, and those that have encouraged business to move
toward safer surfactants.

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

October 25, 2007

Information Collection Request for SDSI Program                         
                                                      Page   PAGE  11 
of   NUMPAGES  17 

EPA Form 6300-2 (x-xx)

