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

The Paperwork Reduction Act

IDENTIFICATION OF THE INFORMATION COLLECTION

	1(a)	Title and Number of the Information Collection

		Title:	Reporting Requirements under the EPA’s Design for the
Environment (DfE) Formulator Product Recognition Program

EPA ICR No.:  2302.01	OMB Control No.:	2070-NEW

	1(b)	Short Characterization

DfE’s Formulator Product Recognition Program (Formulator Program)
recognizes safer products where all ingredients have an environmental
and human health profile showing that they are the safest in their
functional use class.  Under the encouragement of the current Formulator
Program, leading companies have already made great progress in
developing safer, highly effective chemical products.  Since the
program’s inception in 1997, formulators have been using the program
as a portal to OPPT’s unique chemical expertise, information
resources, and guidance on greener chemistry.  DfE Formulator partners
enjoy Agency recognition, including the use of the DfE logo on products
with the safest possible formulations.  In the next three years, DfE
expects much greater program participation due to rising demand for
safer products.  This ICR would enable DfE to accommodate participation
by more than nine formulators each year and enhance program
transparency.

 CleanGredients™, a database of safer cleaning product ingredients,
which identifies safer formulations and makes forming partnerships
easier.  Organized by product functional use class (e.g., surfactants,
solvents, etc.), CleanGredients™ facilitates a green marketplace where
formulators can select functionally appropriate and safer ingredients. 

     The redesign of chemical products offers opportunities to:

Remove hazardous chemicals from formulations before they can enter the
workplace, home, or environment. 

Advance energy and water efficiency, resource conservation, and
innovative technologies. 

Qualify for environmentally preferred product status, increasingly
sought by government, retailer and consumer purchasers. 

     Companies formulate products from a broad range of chemicals with a
variety of applications.  The Formulator Program is particularly
involved with safer cleaning products, holding tank
treatments/deodorizers, industrial coatings, and inks.  Cleaning
products make up the majority of partnership products, and cleaning
product manufacturers make up the lion’s share of demand for program
participation by potential partners.  Third-party profilers review all
cleaning product applications prior to DfE submission.  All other
product applications are submitted directly to DfE for review.  

      The review team applies the DfE assessment methodology, as
described in Attachment B, by carefully reviewing each product
component.  A literature review, and when appropriate, structural
activity relationships, are used to understand each chemical’s health
and environmental characteristics. The review includes all chemicals,
including those in proprietary raw material blends, which ingredient
suppliers share with DfE in confidentiality. The review team then
compares an ingredient’s characteristics to other chemicals in the
same use class, considers possible negative synergies between
ingredients, and places the ingredient on a continuum of improvement
relative to other similar chemicals.  Through its review team and
methodology, DfE provides information to formulators that helps them
select from among the safest chemicals in an ingredient class.  Only
formulations containing exclusively safer ingredients are recognized by
DfE.

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

	2(a)	Need/Authority for the Collection

Authority for the Formulator Program derives from Section 6604(b)(5) of
the Pollution Prevention Act (PPA), 42 U.S.C. 13103(b)(5) [see
Attachment A], which directs EPA to facilitate the adoption of
source-reduction techniques by businesses, and the Toxic Substances
Control Act (15 U.S.C. 2601 et seq.), which encourages safety in
technological innovation in chemistry.  In recognition of this statutory
directive, and through consultation with a broad range of stakeholders,
EPA developed the Formulator Program.  

Formulator Program 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
chemical products.  In turn, the Formulator Program will help businesses
meet 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 Formulator Program
partnership is an important impetus for prioritizing and completing the
transition to safer chemical products.  The Formulator Program is also
needed to promote greater use of safer chemical products by companies
unaware of the benefits of such a change.

DfE has carefully tailored its request for information, and especially
the Formulator application forms, to ensure that it only asks for
information essential to verifying applicants’ eligibility for
recognition.  

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

The information collected by the Formulator Program is not designed or
intended to support regulatory decision-making by EPA. EPA uses the
information collected in the Formulator Program application forms to:
(1) review cleaning or other products and their components; (2) complete
chemical profiles for each product component to determine its key health
and environmental characteristics; and (3) establish a partnership
agreement with the company outlining how the company and EPA/DfE will
work together to continually improve the health and environmental
profile of the product(s).

  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 Formulator 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 Formulator 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 August 18, 2008
(73 FR 34726, June 18, 2008).  EPA received no comments during the
comment period.

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

        SEQ CHAPTER \h \r 1 Under 5 CFR 1320.8(d)(1), OMB requires
agencies to consult with potential ICR respondents and data users about
specific aspects of ICRs before submitting an ICR to OMB for review and
approval. EPA consulted with potential respondents who manufacture
cleaning and other products made of chemical mixtures to get feedback on
the reasonableness of EPA’s cost and burden estimates.

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.  

EPA contacted and received feedback from the following individuals:

Jim McCabe, Clorox, 925-425-6674

Charles Reeves, Sentry Chemical, 770-723-7040

Victoria Finley, Osprey Biotechnics, 941-351-2700 ext. 111

Richard Cottrell, SYSCO, 281-584-1793

      These individuals were supportive of the ICR and said the burden
estimates appeared reasonable.  These respondents are typical of the
types of respondents expected under this ICR.  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 Formulator application forms are designed to be a one-time
information submission for organizations that wish to participate in the
Formulator Program, with the opportunity to renew the partnership
agreement at the end of the three-year partnership period.  This means
that once every three years, the organization will re-submit their
application forms to confirm that no changes have been made to
ingredients; this step is done in response to correspondence from DfE
that reminds organizations of the terms of their partnership agreements.
 If a formulator wishes to submit additional products for recognition
during the course of the three-year partnership, the same application
form would be used.  Without this information collection mechanism, DfE
will not have the ability to assist formulators in developing safer,
highly effective chemical products or to formally recognize formulators
who have successfully done so.

  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

Some information collected by EPA under the Formulator Program involves
confidential business or trade secret information.  The Formulator
Program handles all information claimed as such as confidential business
information in accordance with Agency confidentiality procedures (see 40
CFR part 2, subpart B).  The Formulator Program uses information
provided by formulators solely for purposes related to forming the
partnership and discloses the information only to EPA employees and EPA
contractors cleared for confidential information with a specific need to
know.

  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

The Formulator Program seeks partners from establishments engaged in the
formulation of end-use, for-sale chemical products.

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 the Formulator Program. However, EPA expects that
most applications will come from the following industries:



NAICS Code	Affected Industry

325510	Paint and Coating Manufacturing

325611	Soap and Other Detergent Manufacturing

325612	Polish and Other Sanitation Good Manufacturing

325910	Printing Ink Manufacturing

325992	Photographic Film, Paper, Plate, and Chemical Manufacturing

325998	All Other Miscellaneous Chemical Product and Preparation

Manufacturing



	4(b)	Information Requested

Once a company with an interest in partnership with the Formulator
Program reviews the program materials and decides to apply, the next
step for the organization is to submit the appropriate application form.
 Cleaning product manufacturers will submit an Ingredient Information
Request Form to a qualified third-party profiler before submittal to
DfE.  (See Attachment C for this third-party application form.)  Holding
tank treatment/deodorizing, industrial coating, ink products, and other
manufacturers of innovative and environmentally safer products will
submit an Ingredient Worksheet Form directly to DfE (see Attachment D). 
Applications will be received on an ongoing basis over the three years
covered by this ICR. 

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 DfE or third-party
profiler Web sites.

Data items:

The reporting items include:

Company name and Web site URL;

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

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

Description of all chemical ingredients in product;

An MSDS for the product and each ingredient;

Product performance testing (any method of demonstrating product
performance is acceptable as long as it is a commonly used industry
standard); and

Production volume of all products submitted for recognition.

Respondent activities:

Candidates conduct the following activities in order to complete and
submit the appropriate Formulator Program application form:

Review the Formulator Program application and program information;

If a formulator of cleaning products:  fill out and submit 3rd party
information request form, and establish agreement with 3rd party to
review cleaning product application;

If not a formulator of cleaning products, submit chemical information to
DfE;

If a formulator of cleaning products: Submit 3rd party generated
chemical summary report to DfE;

Establish partnership agreement with DfE; and

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 the Formulator Program, EPA engages in the following activities
related to the Formulator application and decision process.

Distribute forms to potential participants, and maintain downloadable
PDF versions on the Formulator Program Web site;

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

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

Apply EPA’s chemical tools and expertise to understand toxicological
characteristics of chemical ingredients and to ensure that they are the
safest within their functional use class; 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

Cleaning product manufacturers will be able to obtain an Ingredient
Information Request Form in hard copy from EPA or by downloading it from
the Web site of the third-party profiler.  Non-cleaning product
manufacturers will be able to obtain the Ingredient Information Request
Form in hard copy from EPA or by downloading it from the Formulator
Program Web site. The completed forms can be faxed, mailed, or, if they
do not contain CBI or Trade Secret information, they can be scanned and
emailed 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 proof of the
list of ingredients (e.g., bills of lading, invoices) or other relevant
documentation at any time to confirm that candidates have achieved the
criteria for recognition.

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

EPA expects that some of the participants in the Formulator 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 an application for recognition 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.

The data collection mechanism for the Formulators Program is the
Ingredient Information Request Form for cleaning products and the
Ingredient Worksheet for non-cleaning products.  In an effort to
minimize burden and cost, both forms were designed to contain answers
that do not require significant research.  

	6(a)	Estimating Respondent Burden

The average respondent burden is estimated to be 20 hours for cleaning
product formulators and 17 hours for non-cleaning product formulators
(see Exhibit 6.2).  The burden associated with cleaning products is
higher because cleaning product manufacturers typically submit a greater
number of products for recognition per application than non-cleaning
product manufacturers.  EPA used professional judgment to arrive at a
burden estimate and then consulted representatives from the participant
categories to make sure the burden estimates were reasonable (see
section 3(c)).  

EPA expects that for a typical cleaning product formulator, program and
application review will take about 2 hours (1 managerial, 1 technical). 
Filling out and submitting third-party information request forms will
take about 5 hours (4 technical, 1 clerical), and then establishing an
agreement with the third party will take about 3 hours (1 managerial, 1
technical, 1 clerical).  Submitting a summary report to DfE will take
about 2 hours (1 managerial, 1 technical).  Finally, establishing a
Partnership Agreement DfE will take 3 hours (1 managerial, 2 technical).
 

For a typical non-cleaning product formulator, program and application
review will take 2 hours (1 managerial, 1 technical).  Filling out and
submitting the DfE ingredient worksheet will take about 5 hours (4
technical, 1 clerical).  Finally, establishing a Partnership Agreement
with DfE will take 5 hours (1 managerial, 4 technical).  

In addition to the burden associated with first-time submission of
application forms, each formulator has the opportunity to renew its
Partnership Agreement at the end of the three-year partnership period. 
This means that once every three years, the formulator re-submits its
application for each partnership product to confirm that no changes have
been made to ingredients.  EPA then evaluates the application.  EPA
estimates that the partnership renewal process will take 5 hours (4
technical, 1 clerical) for cleaning and non-cleaning product
formulators.  For purposes of this ICR, EPA expects that all cleaning
and non-cleaning product formulators will choose to renew their
partnerships.  Furthermore, EPA anticipates that one in ten cleaning and
non-cleaning product formulators will need to make improvements to their
formulations so that they contain the safest ingredients within each
functional use class; in these cases, a new partnership approval
process, as described above, will be triggered.  The associated burden
for completing the new partnership approval process is assumed to be the
same as first-time submission.  For purposes of estimating annual cost
and burden in Exhibit 6.2, it is assumed that one-third of all
formulators over the three-year period of this ICR will renew their
partnership agreements each year, and that one in ten formulators will
need to go through a new partnership approval process.

6(b)	Estimating Respondent Costs

EPA estimates an average loaded hourly labor rate (base hourly rate plus
fringe and overhead) of $68 for managerial staff, $55 for technical
staff, and $27 for clerical staff.  These three labor rate estimates are
based upon manufacturing industry wage data from the Bureau of Labor
Statistics (BLS) Employer Costs for Employee Compensation, Supplementary
Tables from September 2007.  The hourly labor rates include a 17%
overhead; this overhead rate is used for consistency with OPPT economic
analyses for two major rulemakings: Wage Rates for Economic Analyses of
the Toxics Release Inventory Program and the Revised Economic Analysis
for the Amended Inventory Update Rule: Final Report.  In addition, the
hourly labor rates have been rounded for the purposes of this ICR.  The
type of staff needed to complete the Formulator’s application forms
and their associated hourly labor rates were verified by contacting
representatives from the participant categories.

The derivation of labor rates for managerial, technical, and clerical
staff is shown in exhibit 6.1 below.

  SEQ CHAPTER \h \r 1 Exhibit 6.1.  Derivation of Loaded Wage Rates

Labor category	Wage	Fringe Benefit	Fringes as % wage	Overhead % wage
Fringe + overhead factor	Loaded Wages	Loaded Wages (rounded)

	(a)	(b)	(c)=(b)/(a)	(d)	(e)=(c)+(d)+1	(f)=(a) x (e)

	Managerial	$41.40	$19.74	47.68%	17%	1.65	$68.18	$68.00

Professional/

Technical2	$33.25	$16.54	49.74%	17%	1.67	$55.44	$55.00

Clerical2	$16.40	$8.28	50.49%	17%	1.67	$27.47	$27.00



In exhibit 6.2 we show the breakdown of burden costs, assuming 20 hours
for cleaning product manufacturers and 17 hours for non-cleaning product
manufacturers.  The third-party verification process for cleaning
products also adds a operating and management (O&M) cost of about
$13,200 per company per application.  This cost estimate is from NSF
International, which has experience conducting third-party analysis of
ingredient characteristics.  For this ICR, it is assumed that the
typical cleaning product manufacturer will submit four products in an
application.  Each product is assumed to contain 2 ingredients at $500
each, 2 proprietary ingredients at $1,000, and 1 CleanGredients™
ingredient at no charge, for a total of $3,000 per product.  In
addition, a $3,300 administrative fee is assumed. The total will be
$13,200 per company per application.  It is assumed that the typical
non-cleaning product manufacturer will submit one product per
application.  No additional capital or O&M costs are incurred by
respondents under this ICR.

  SEQ CHAPTER \h \r 1 Exhibit 6.2.  Estimated Burden and Costs to
Respondents

Collection activity	Hours and Costs Per Respondent	Total Hours and Costs

	Manager

$68/Hr	Technical

$55/Hr	Clerical

$27/Hr	Response Hours/Yr	Labor Cost/Year	Capital

Cost	O & M Cost*	Number of Respon.**	Total Hours/Yr	Total Cost/Yr

Cleaning Products

Review application and program information	1	1	0	2	$123	0	--	30	60
$3,690

Fill out and submit 3rd party information request form	0	4	1	5	$247	0	--
30	150	$7,410

Establish agreement with 3rd party	1	1	1	3	$150	0	$13,200	30	90	$400,500

Submit summary report to DfE	1	1	0	2	$123	0	--	30	60	$3,690

Negotiate / establish Partnership Agreement with DfE	1	2	0	3	$178	0	--
30	90	$5,340

Renew partnership, with no changes needed	0	4	1	5	$247	0	--	29	145
$7,163

Subtotal	Varies	Varies	Varies	20	$1,068	0	$13,200	29	595	$427,793

Non-Cleaning Products

Review application and program information	1	1	0	2	$123	0	0	4	8	$492

Fill out and submit DfE ingredient worksheet	0	4	1	5	$247	0	0	4	20	$988

Negotiate / establish Partnership Agreement with DfE	1	4	0	5	$288	0	0	4
20	$1,152

Renew partnership, with no changes needed	0	4	1	5	$247	0	0	3	15	$741

Subtotal	Varies	Varies	Varies	17	$905	0	0	3	63	$3,373

TOTAL	Varies	Varies	Varies	37	$1,973	0	$13,200	32	658	$431,166

* The cost for third-party review and verification assumes that the
typical application submitted by a cleaning product manufacturer will
contain four products.  Each product will contain 2 ingredients at $500
each and 2 proprietary ingredients at $1,000, for a total of $3,000 per
product.  Also assumes a $3,300 administrative fee. The total will be
$13,200 per company per application.

**This column reports the number of respondents after accounting for the
partnership renewal process.  Assumes that one in ten formulators will
need to make changes to their formulations and go through a new
partnership process which includes same collection steps – i.e., 1 of
29 cleaning product formulators (for a total of 30) and 1 of 3
non-cleaning product formulators (for a total of 4).  6(c)	Estimating
Agency Burden and Costs 

  SEQ CHAPTER \h \r 1 Exhibit 6.3 presents the estimated Agency burden
hours and costs associated with the information collection activities
under this ICR.  EPA based its burden estimates on its experience
managing other voluntary programs.

Agency labor costs are calculated based on hourly basic rates for
federal employees in the Washington-Baltimore area published by the
Office of Personnel Management effective January 2008.  The average
hourly labor rate for managerial staff is estimated as the rate for a
GS-13 Step 5 employee, for technical staff as a GS-10 Step 10 employee,
and for clerical staff as GS-5 Step 1.  These GS-level assumptions are
consistent with those used in past EPA OPPT ICRs.  The hourly rates were
multiplied by an assumed loading factor of 1.6 to reflect Federal fringe
benefits and overhead.  This loading factor is from an EPA guide,
Instructions for Preparing Information Collection Requests (ICRs) (OPPE,
1992, page 30, footnote 9).  

The resulting average hourly labor rates, rounded to the nearest dollar
amount, are $72 for managerial staff, $53 for technical staff, and $24
for clerical staff.  The Agency expects most activities related to this
ICR to be performed by managerial staff (25 percent) and technical staff
(75 percent).

Exhibit 6.3.  Annual Agency Burden/Cost 

Collection activity	Hours and Costs Per Respondent	Total Hours and Costs

	Manager

$72/Hr	Technical

$53/Hr

	Agency Hours/Yr	Labor Cost/Year	Capital/

Startup Cost	O & M Cost	Number of Respon.*	Total Hours/Yr	Total Cost/Yr

Cleaning Products

Review program information	0	1	1	$53	0	0	30	30	$1,590

Review 3rd-party summary	0	7	7	$371	0	0	30	210	$11,130

Negotiate / establish Partnership Agreement with formulator	2	4	6	$356	0
0	30	180	$10,680

Review partnership renewal, with no changes needed	1	1	2	$125	0	0	29	58
$3,625

Subtotal	Varies	Varies	16	$905	0	0	29	478	$27,025

Non-Cleaning Products

Review program information	0	1	1	$53	0	0	4	4	$212

Review product submissions and complete chemical profiles	0	29	29	$1,537
0	0	4	116	$6,148

Negotiate / establish Partnership Agreement with formulator	2	6	8	$462	0
0	4	32	$1,848

Review partnership renewal, with no changes needed	1	1	2	$125	0	0	3	6
$375

Subtotal	Varies	Varies	40	$2,177	0	0	3	158	$8,583

TOTAL	Varies	Varies	56	$3,082	0	0	32	636	$35,608

*This column reports the number of respondents after accounting for the
partnership renewal process.  Assumes that one in ten formulators will
need to make changes to their formulations and go through a new
partnership process which includes same collection steps – i.e., 1 of
29 cleaning product formulators (for a total of 30) and 1 of 3
non-cleaning product formulators (for a total of 4).  SEQ CHAPTER \h \r
1 6(d)	Estimating the Respondent Universe and Total Burden and Costs

EPA estimates that 96 formulators will submit applications over the
three-year life of the clearance.  EPA expects the participation will
ramp up over the three year period, but for the purposes of estimating
annual cost and burden in Exhibit 6.2, it is assumed that 32 formulators
will submit applications per year.  This estimate is based on historical
data and the assumption that participation will increase over the next
three years in response to greater consumer demand for green products. 
Furthermore, EPA estimates that of the applications, about 90 percent
(or 29 per year) will be cleaning products, with the remainder being
non-cleaning products.  The annual burden hours and cost associated with
this information collection are 658 hours and $431,166, respectively.

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

a.	Respondent Tally

Exhibit 6.4 below summarizes the total annual estimated respondent
burden and cost.  These estimates represent the average burden in any
given year over the three years covered by this ICR.

Exhibit 6.4.  Total Annual Estimated Respondent Burden and Cost Summary

Total # of Respondents	Burden Hours	Annual Cost

32	658	$431,166



b.	Agency Tally

Exhibit 6.5 below summarizes the total annual estimated agency burden
and cost.  These estimates represent the average burden in any given
year over the three years covered by this ICR.

							

Exhibit 6.5.  Total Annual Estimated Agency Burden and Cost Summary

Burden Hours	Annual Cost

636	$35,608



	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 20 hours per response for formulators of cleaning products and 17
hours per response for formulators of non-cleaning products, 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.

  SEQ CHAPTER \h \r 1 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-2008-0219.  The docket is
available for public viewing at the Pollution Prevention and Toxics
Docket in the EPA Docket Center (EPA/DC).  The EPA/DC Public Reading
Room is located in the EPA West Building, Room 3334, 1301 Constitution
Ave., NW., Washington, DC.  The EPA/DC 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 EPA/DC Public 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 through the Federal Docket Management System (FDMS)
at     HYPERLINK "http://www.regulations.gov"  www.regulations.gov . 
Use FDMS to submit or view public comments, access the index listing of
the contents of the public docket, and to access those documents in the
public docket that are available electronically.  Once in the system,
select “search,” then key in the docket ID number identified above. 
Also, you can send comments to the Office of Information and Regulatory
Affairs, Office of Management and Budget, 725 17th Street, NW,
Washington, DC 20503, Attention: Desk Office for EPA.  Please include
the EPA Docket ID No. EPA-HQ-OPPT-2008-0219 and OMB control number
2070-NEW in any correspondence.

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-2008-0219.  These attachments are available for online
viewing at www.regulations.gov or otherwise accessed as described in
section 6(g) 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:	Design for the Environment Formulator Program Elements: A
Discriminating and Protective Approach to Cleaning Product Review and
Recognition

Attachment C:	Formulation Information Request for Cleaning Products



Attachment D:	DfE Formulator Initiative:  Ingredient Worksheet







  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

Design for the Environment Formulator Program Elements: A Discriminating
and

Protective Approach to Cleaning Product Review and Recognition

Design for the Environment Formulator Program Elements:  

A Discriminating and Protective Approach to Cleaning Product 

Review and Recognition 

January 2008

Situated in the U.S. EPA’s Office of Pollution Prevention and Toxics
(OPPT), the Design for the Environment (DfE) Formulator Program is a
product formulator’s gateway to OPPT’s unique chemical expertise,
information resources, and guidance on greener chemistry.  The program
gathers hazard information on chemical ingredients and works with
OPPT’s science experts to assess this information and compare the
relative safety of chemicals.  

Since 1997, DfE has offered recognition to those companies who design
for the environment and human health by using only safer chemicals. To
date around 300 chemical products have been recognized by the program. A
complete list of partner companies and products can be found at:  
HYPERLINK "http://www.epa.gov/dfe/pubs/projects/formulat/formpart.htm" 
http://www.epa.gov/dfe/pubs/projects/formulat/formpart.htm . 

What Makes DfE Formulator Review Unique?  The DfE Program is distinct
from all other product recognition or ecolabeling programs because of
two defining characteristics:  its assessment methodology and its
technical review team.  The DfE technical review team has many years of
experience and is highly skilled at assessing chemical hazards, applying
predictive tools, and identifying safer substitutes for chemicals of
concern.  

The review team applies the DfE assessment methodology by carefully
reviewing each product component, starting with the chemical
component’s structure, to determine its key health and environmental
characteristics. (The review includes all chemicals, including those in
proprietary raw material blends, which manufacturers share with DfE in
confidentiality).  The review team then compares an ingredient’s
characteristics to other chemicals in the same use class, considers
possible negative synergies between ingredients, and places the
ingredient on a continuum of improvement relative to other similar
chemicals. 

Through its review team and methodology, DfE provides information to
formulators that helps them select from among the safest chemicals in an
ingredient class.  The approach is adaptable to changing circumstances
and new information, emphasizing continuous improvement as the
opportunities for safer formulations grow with chemical innovation.

How Does DfE’s Component-Based Review Compare with Other Product-Based
Approaches?  The following examples showcase some of the key benefits of
DfE’s component-based review and the extra measure of protection it
often provides:

DfE uncovers chemicals of concern that can be masked by raw material
blends or by dilution in water.  By focusing at the component level and
on key inherent characteristics, DfE is able to carefully scrutinize
formulations and make meaningful calls on potential concerns.  For
example, a surfactant that is acutely toxic to aquatic organisms and
environmentally persistent can appear to pose a low concern when blended
with other less toxic and less persistent surfactants.  Similarly,
water, typically the largest percentage ingredient even in concentrates,
can mask the effects of a hazardous chemical.

DfE spots negative synergies between product components.  These
potentially dangerous chemical combinations pose concerns for both acute
and longer-term effects.  For example, oxidizing agents, like hydrogen
peroxide, can release the sensitizing potential of certain citrus
fragrances; another example, mixing nitrogen-containing compounds with
amines will create nitrosamines, potent carcinogens.

DfE uses its expert knowledge and predictive tools to supplement lists
of chemicals of concern.  Few chemicals in commerce have been adequately
tested, especially for chronic effects, like cancer and developmental
toxicity and thus lists of chemicals with these effects are partial at
best.  DfE uses its knowledge of the structural similarities between
chemicals and its predictive models to flag product components with
similar potential effects.  

DfE screens all fragrances and dyes for chemicals that may pose serious
health or environmental effects. Some of the chemicals of most potential
concern in cleaning products are those in fragrances and dyes.  Chemical
ingredients in these classes can include sensitizers, carcinogens, and
environmentally toxic and persistent compounds.  Small quantities
don’t necessarily mean small hazards: A person, once sensitized to a
chemical, can have an allergic response even if exposed at levels below
those that initially induced sensitization.

DfE recommends safer substitutes for chemicals of concern. 
Sustainability requires innovation and continuous improvement.  The DfE
program works directly with EPA’s Green Chemistry specialists to
identify and recommend safer chemicals to its formulator partners,
continuously raising the bar and redefining the meaning of
environmentally preferable products.  

The following matrix highlights many of the elements reviewed by the DfE
Formulator Program team.  The matrix should help purchasing entities and
others understand what DfE considers in its review, what its recognition
means, and how they should view products that carry the DfE logo.  DfE
compares and balances product characteristics in determining the
appropriateness and type of DfE recognition.

Review elements	Assessment Approach	Comments

Aquatic Toxicity - Acute	Acute aquatic toxicity for a component is
evaluated in conjunction with the chemical’s other attributes; focus
is on the key distinguishing characteristics that make one chemical
safer than another. For example, all high-functioning surfactants have
high aquatic toxicity (low LC50 values). Safer surfactants are those
that are readily biodegradable and do not degrade to chemicals that are
persistent or toxic.

	Aquatic Toxicity - Chronic	DfE considers data if available or
estimation models, and in particular limits those components whose
aquatic toxicity increases through long-term (chronic) exposure.

	Acute Dermal, Oral and Inhalation Toxicities (LD50)	When data are
available, DfE follows the UN’s Globally Harmonized System for rating
acute dermal, oral and inhalation toxicities. No components classified
under “Danger” are found in DfE-recognized products. At a minimum,
each component has an: 

Acute dermal toxicity LD50 > 1000 mg/kg.

Acute oral toxicity LD50 > 300mg/kg, and

Acute inhalation toxicity LC50 >10 mg/L.

For components without data, DfE relies on the judgment of its technical
experts to identify chemicals that, by analogy, pose a potential acute
dermal toxicity hazard.

	Alkylphenol ethoxylates (APEs)	DfE-recognized products do not contain
APEs. APEs, like all surfactants, are compared based on their key
distinguishing characteristics:

Rate of biodegradation,

Aquatic toxicity, and

Degradation products.

APEs do not have acceptable profiles because they degrade to products
that are increasingly toxic and are potential endocrine mimics. 	DfE has
identified surfactants that are safer than APEs, and have comparable
performance and price. In the context of its product reviews, DfE
provides this information on safer substitutes to its formulator
partners.

See also the section titled ‘Surfactants’.

Bioaccumulation	DfE uses data, models, and EPA’s expert judgment to
assess a component’s potential to bioaccumulate. Bioaccumulation
potential is reviewed in conjunction with a chemical’s other
attributes. Depending upon certainty of effect, component class, and
percentage in the formulation, DfE limits components that may
bioaccumulate.

	Biodegradation	DfE evaluates biodegradation for all components in
conjunction with a chemical’s other attributes; focus is on the key
characteristics that make one chemical safer than another. For
ingredients, like surfactants, where rate of biodegradation is key to
safer chemistry, a DfE-recognizable chemical is readily biodegradable
and, very importantly, its degradation products are of low concern. 

	Carcinogenicity 	DfE-recognized products do not contain known, probable
or possible human carcinogens as defined by: 

IARC,

NTP,

U.S. EPA, and

OSHA.

In addition, DfE reviews cancer concerns through:

Published cancer studies,

Potential synergistic effects between components that may produce
carcinogenic byproducts (e.g. nitrosating agents and amines form the
carcinogenic nitrosamines),

EPA’s ONCOLOGIC model, and

EPA’s expert judgment.  	Few chemicals in commerce have been
sufficiently tested to determine their potential for human
carcinogenicity. In the absence of testing, EPA’s ONCOLOGIC model and
expert judgment help fill data gaps. The referenced lists cover only
those chemicals which have been fully evaluated by the agencies. It is
likely that other carcinogenic, mutagenic, and reproductively toxic
(CMR) chemicals have not yet been identified.



Other Chronic Health Effects

_____________

Basic Internal Organ Effects (Including Endocrine System & Blood)

_____________

Central Nervous System (CNS) Effects	Depending on component class,
certainty of effect, and percentage in formulation, DfE limits
components that may pose other potential chronic health or internal
organ effects. Potential concerns for chronic health effects are
identified through published studies, internal EPA databases, and
comparison to chemical analogs. 

	Compostability	DfE considers wipe composition and ability to decompose
as key characteristics for disposable cleaning wipes when they are the
intended method of application for a cleaning formulation.  At a
minimum, wipes must be made entirely of compostable material. 



	 Dibutyl phthalate	DfE-recognized products do not contain this and
other phthalates of concern, based on key characteristics for
plasticizers.	Dibutyl phthalate, a plasticizer, can also be found in
fragrances.

Energy Efficiency	 DfE considers the energy efficiency of  products by
comparing product efficiency to that typical of the class, recognizing
the important source reduction benefits from this efficiency measure.



	Eutrophication	DfE-recognized products do not contain inorganic
phosphates (known to be present or intentionally added), because of
their potential for eutrophication. 	Algal blooms possible at
concentrations of less than 200 parts per billion (about 0.000002%) in
96 hours (certain inorganic phosphates have produced exponential growth
of green algae at levels as low as 50 parts per billion). 

 Flammability	DfE takes note of product flashpoint as appropriate and
seeks to ensure low concerns for combustibility.	Flashpoint is generally
not a concern when dealing with water-based mixtures. Flammable liquids
are regulated by: 

49CFR173.120 (a) (5) - Flammable Liquid Definition

49CFR173.150 (e) Aqueous Solutions of Alcohol

40CFR261.21 (a) (1) Characteristic of Ignitability

Fluorosurfactants	Based on EPA's concerns for persistence,
bioaccumulation in humans, and potential toxicity, DfE-recognized
products do not contain any fluorosurfactants that have a fluorinated
chain of eight or more carbons (C8). All fluorosurfactants that do not
have a C8 or longer chain will be reviewed on a case-by-case basis by
DfE. 	The ideal, green chemistry surfactant and surface treatment
chemical, including wetting and leveling agents, would be a chemical
that readily degrades to non-toxic degradants, has low toxicity, does
not persist, or metabolize to chemicals of concern in humans or other
species, and performs well when compared to traditional wetting agents.
As green chemistry innovations occur in this ingredient class (as with
all ingredient classes), DfE may shift its continuum of improvement and
no longer allow previously acceptable surfactants and surface treatment
chemicals. 

Fragrances	DfE works directly with fragrance houses to improve their
formulations. Components are screened for: 

Sensitization,

Carcinogenicity,

Mutagenicity,

Reproductive toxicity,

Environmental persistence, 

Aquatic toxicity, and

Other hazard characteristics. 

	Following IFRA’s Code of Practice may not be sufficiently protective
when a fragrance is added to a cleaning product. The sensitization
potential of terpenes (considered both fragrances and solvents) can be
released when combined with oxidizers, such as hydrogen peroxide.

Heavy metals	DfE-recognized products do not contain heavy metals. 
Unavoidable, de minimis levels may be present, e.g., from inorganic
materials mined from the earth.

Labeling Requirements	Memorandum of Understanding requires each partner
company to provide its customers with information on environmental and
worker safety matters.	OSHA, DOT, and other authorities require
manufacturers to provide handling and other worker safety information.

Mutagenicity	Depending on component class and certainty of effect, DfE
limits components that are potential mutagens. Potential concerns for
mutagenicity are identified through published studies, internal EPA
databases, and comparison to chemical analogs. DfE often looks at
multiple mutagenicity test results, and exercises expert judgment in
interpreting and characterizing the potential hazard.

	Ozone-depleting compounds	DfE-recognized products do not contain
ozone-depleting compounds.

  HYPERLINK "http://www.epa.gov/ozone/science/ods/index.html" 
http://www.epa.gov/ozone/science/ods/index.html 

	The Montreal Protocol (1987) initiated the phase-out of HCFCs and
banned almost all CFCs, including those used as propellants in cleaning
products.

Packaging	DfE encourages the use of environmentally friendlier
packaging, but does not require specific types of packaging.

	Photochemical Smog, Tropospheric Ozone Production, and Indoor Air
Quality	DfE seeks to minimize VOCs and limits components that are also
Hazardous Air Pollutants (HAPs) or are on EPA’s Toxics Release
Inventory (TRI)  DfE strives to optimize the health and environmental
preferability of products. The lowest possible VOC-level may not
correspond to the safest formulation.



	Product Performance Testing	To ensure a baseline measure of
performance, DfE asks all partners to demonstrate that their products
perform effectively.  Potential partners may submit appropriate test
results as specified in Appendix I or provide equivalent performance
tests agreed upon by DfE. 

	Quality Assurance/Control	The Partnership Agreement between EPA/DfE and
the partner company affirms that those ingredients disclosed to EPA
during the product review process are in fact the only ingredients
intentionally added or known to be present. EPA is currently exploring
additional methods such as composition analysis for ensuring further
quality control.



	Reproductive and Developmental  Toxicity	DfE reviews reproductive
toxicity concerns through: 

Published studies on reproductive toxicity, and

EPA’s expert judgment. 

In addition, DfE supplements its reviews with the following lists: 

To minimize potential for dermal and eye irritation or injury, product
pH should be ≥ 2 and ≤ 11.5. Depending on percentage in the
formulation, DfE limits components that are suspected or known severe
skin and eye irritants.	Most cleaning products have ingredients, like
surfactants, that are expected skin and eye irritants, especially at
concentrated levels. OSHA requires product-level irritation information
on all MSDSs, if any positive results are available. 

Skin Sensitization	Depending on component class, certainty of effect,
and percentage in the formulation, DfE limits components that are
suspected or known skin sensitizers. DfE reviews product formulations
for negative synergistic effects between components (e.g. byproducts of
limonene and oxidizing agents). 	Sensitization potential often depends
on component class and chemical synergies. OSHA requires product-level
sensitization information on all MSDSs, if any positive results are
available.

Surfactants	DfE has developed a screen for surfactants that considers
acute aquatic toxicity and biodegradation as key characteristics for
this chemical class.  Components that have a relatively high acute
toxicity (<10 ppm) must biodegrade within a 10-day window.

	  HYPERLINK "http://www.epa.gov/dfe/pubs/projects/gfcp/index.htm" 
http://www.epa.gov/dfe/pubs/projects/gfcp/index.htm 



Training	Memorandum of Understanding requires each partner company to
provide its customers with information on environmental and worker
safety matters.	OSHA, DOT, and other authorities require manufacturers
to provide handling and other worker safety information.



Appendix I: Product Performance Testing under EPA’s Design for the
Environment Formulator Program

DfE believes performance testing requirements should be product category
specific, and will accept any valid and scientifically sound method of
demonstrating product performance. Examples of performance requirements
that are acceptable to DfE include but are not limited to:

Glass Cleaners – Meets user requirements for cleaning, streaking and
smearing when tested according to CSPA method DCC09 or equivalent method
agreed upon by EPA DfE.

General Purpose Cleaners – Meets user requirements for soil removal on
relevant substrates when tested according to ASTM method D4488-95,
CAN/CGSB 2-GP-11, Method 20.3, or equivalent method agreed upon by EPA
DfE.

Carpet Cleaners – Perform equal to or better than nationally
recognized carpet cleaners in the same category using CSMA DCC-03 and
AATCC Test Method 171-1995 or equivalent method agreed upon by EPA DfE.

Washroom Cleaners – Meets user requirements for soil removal using
ASTM D5343 or equivalent method agreed upon by EPA DfE.

ATTACHMENT C

Formulation Information Request for Cleaning Products

Formulation Information Request for Cleaning Products

Why did I receive this request?

For a cleaning product to bear the EPA Design for the Environment (DfE)
logo, a company must first complete a hazard-based third party review of
all the ingredients that make up your product. The third party reviewer,
NSF International, will review each ingredient for environmental and
human health information, confirm that your components meet the DfE
Formulator criteria and then will recommend your product to EPA. The
attached forms will initiate this review.  Once NSF International has
received the forms below, a business contract will be sent to your
company with a cost estimate for this review. 

Who is NSF?

 

NSF International (NSF) is an independent, not-for-profit organization
of scientists, engineers, technicians, educators, and analysts. NSF
currently provides testing, certification, and audit services for more
than 130,000 products in 82 countries worldwide. It is a trusted neutral
non-governmental agency, serving government, industry, and consumers in
achieving solutions to problems relating to public health and the
environment since 1944. The mission of NSF is to provide clients and the
general public with objective, high quality, timely, third-party
certification services. Services include development of consensus
standards, voluntary product testing and certification with policies and
practices which protect the integrity of registered Marks, education and
training, and research and demonstration, all relating to public health
and the environmental sciences.

What information do I provide?

To begin the review process of a product, a Formulator must first submit
the full product information; this will consist of information on all
ingredients in the product (no minimum concentration). Each ingredient
should have a single CAS# associated with it, however, if an ingredient
is made up of more than one component, all CAS#s should be listed on the
Product Information Form. To clarify, an ingredient is the whole
ingredient as sold to a formulator and a component is each individual
chemical within that ingredient. If your company does not have access to
this information due to the proprietary nature of the ingredient, please
provide the supplier’s name and contact information. The Form must
include CAS#s, chemical names, trade names, and % in the formulation for
each component in the ingredient.  Please submit:

Product Information Request Form 

Complete sections 1-3 only once per submission 

Complete sections 4 for each product

A MSDS for the product and each ingredient

Product performance testing: Any valid and scientifically sound method
of demonstrating product performance is acceptable. 

Any other supplemental product or ingredient environmental health and
safety information. If available, please submit:

Biodegradation tests on individual ingredients

Acute aquatic toxicity tests on product as a whole or individual
ingredients

Human health and safety tests

Will my information remain confidential?

Only NSF authorized personnel are permitted accesses to the information
provided on this form.  The security of this form and the information it
contains is maintained through our confidential business information
procedures and will not be revealed or provided to applicants, their
suppliers, or other parties without your company’s prior written
consent.



Product Information Request Form

	

NSF USE ONLY

      	





The information requested on this form is important to NSF.  

Please complete and return this form as soon as possible, or call
651-493-4247 for assistance.

Company information: 

Company name	  FORMTEXT        		Company contact	  FORMTEXT 
      		

Address	  FORMTEXT        		Telephone number	(  FORMTEXT 
      )  FORMTEXT        	

  FORMTEXT        		FAX number	(  FORMTEXT        ) 
FORMTEXT        	

  FORMTEXT        		Email	  FORMTEXT        		

2.   Certification statement:

I hereby certify that, to the best of my knowledge, the information
provided to NSF is accurate and complete.  

 

Signature   FORMTEXT        		Date   FORMTEXT       
	

  FORMCHECKBOX   For forms submitted electronically, check this box to
indicate agreement to the Certification Statement above (required).

Typed or printed name   FORMTEXT        	

Position/Title   FORMTEXT        	

3.  Return instructions:

To send by e-mail, completely fill out the form, and type your name and
contact information in Section 4.  Check the box indicating your
agreement with the certification statement.  Send your e-mail to  
HYPERLINK "mailto:tmcgrath@nsf.org"  tmcgrath@nsf.org .

To send by fax, completely fill out and sign the form, then fax to
734-827-3871.  This fax number goes to a secure computer in the
Toxicology Services department of NSF International.

To send by U.S. mail or courier, insert completed form in an envelope
marked "Confidential Business Information," seal in an outer envelope,
and return to:

	Amy Rice

	Toxicology Department, Formulator Program 

NSF International                                    

789 Dixboro Road

Ann Arbor, MI.  48105

USA 

Product information:

  Product Name/Trade designation

  FORMTEXT        

  Product general information:

Type of product (all purpose, glass cleaner, floor care…etc.)  
FORMTEXT          

Consumer Product   FORMCHECKBOX   or  Industrial & Institutional Product
  FORMCHECKBOX  

pH of product:   FORMTEXT         

Check here if product is an aerosol   FORMCHECKBOX  

Check here if product is registered with EPA Office of Pesticides  
FORMCHECKBOX  

Production volume (lbs/yr)   FORMTEXT        _______

Check here if product performance data is attached to the submission  
FORMCHECKBOX  

      4.3    Ingredient Worksheet:  For sample form and instructions,
please see the last page of this form.

CAS No.

[1]	Chemical Name

[2]	Ingredient Class (Surfactant, Fragrance, solvent, builder, chelator,
pH adjustor…etc)

[3]	Trade Name

[4]	Supplier(s) (Include

Alternate Suppliers)

1 Supplier per line

[5]	Other supporting information: Number of ethoxylates, average chain
length…etc.

[6]	%

Composition [7]	

Proprietary?

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Omission of information may significantly delay the completion of the
review process.

ALL INFORMATION CONTAINED ON THIS PAGE IS CONFIDENTIALFormulation
information:  What should I enter in each column?

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␃กᢄ崀ᢄ愀Ĥ摧䠏Yጀr finding specific CAS numbers (e.g.,  
HYPERLINK "http://chem.sis.nlm.nih.gov/chemidplus/cmplxqry.html" 
http://chem.sis.nlm.nih.gov/chemidplus/cmplxqry.html ).  All CAS numbers
are up to nine digits, which are separated into three groups by hyphens.
 The first part of the number, starting from the left, has up to six
digits; the second part after the first hyphen has two digits.  Finally,
the third part of the CAS number following the last hyphen is single
digit.  For example, a CAS number may look 123456-12-1.  If it is not in
this format, it is not a valid CAS number. If you cannot determine a CAS
number for an ingredient, leave this area blank.

	

[2]  The chemical name for each component can be found on the MSDS.     
   

[3]	The ingredient class can refer to: surfactants, solvents, chelators,
fragrances, preservatives/biocide, builders, hydrotropes, sequestrants,
dispersants, sanitizer, dyes/colorants, enzyme/microorganisms,
fragrances, and other.

[4]  The trade name is the unique name or number of the ingredient as
you buy it from your supplier.  This information can be obtained from
your purchasing department.  

[5]  The supplier is the company from whom you buy this ingredient.  If
you know that your supplier is a distributor, and you know the name of
the company that manufactures the ingredient, please enter both company
names here.  Write (D) after the distributor’s name, and (M) after the
manufacturer’s name.  For each ingredient that you buy from more than
one supplier, please enter each chemical name, trade name, supplier, and
% on a separate line.

[6] A single surfactant CAS number may represent a wide range of carbon
chain length and/or number of ethoxylates. Detailed information on the
specific chemical you are using will help NSF perform an accurate review
of your chemical.

[7]  The percentage in the ingredient must be completed for each
component.  The total of all components must always equal 100%.

[8] Check here if your product contains an ingredient purchased from an
outside company and your company is not aware of the exact composition
of that ingredient (i.e. you do not have CAS#s for a proprietary
ingredient).     

An example of a completed formulation is shown below:

CAS No.

[1]	Chemical Name

[2]	

Ingredient Class 

[3]	Trade Name

[4]	Supplier(s) (Include

Alternate Suppliers)

1 Supplier per line

[5]	Other supporting information: Number of ethoxylates, average chain
length…etc.

[6]	%

Composition [7]	

Proprietary?

[8]

68131-39-5	Alcohols, Ethoxylated	Surfactant	Surfactant 1	Company A
C12-15, Average 7EO	14

	67762-38-3	Methyl soyate	Solvent	Solvent 1	Company B	C12-18	36

	?	?	Builder	Builder 1	Company C	?	5	X

7732-18-5	Water	Solvent	Solvent 2	Company D

45

	

ATTACHMENT D

DfE Formulator Initiative:  Ingredient Worksheet



Product Information

Company Name:

	Is the product registered with EPA Office of Pesticides? (Y/N)







Product:

	Is the product an aerosol? (Y/N)









Enter pH of product









Enter Date of Form Submittal







		Chemical Name	CAS Registry #	Trade Name	% by weight in formula

Surfactant











Hydrotrope











Builder











Sequestrant











Dispersant











Solvent











Sanitizer











Enzyme/

Micro-organism











Preservative/Biocide











Fragrance











Colorant











Other





















Total = 100%



 “Green to Gold: How Smart Companies use environmental strategy to
innovate, create value, and build competitive advantage" by Daniel Esty
and Andrew Winston, Yale University Press, New Haven, 2006

 Bureau of Labor Statistics (BLS) Employer Costs for Employee
Compensation, Supplementary Tables.  From Supplementary Table 2,
Employer costs per hour worked for employee compensation and costs as a
percent of total compensation: Private industry workers in manufacturing
industries, by occupational group, establishment size and bargaining
status, September 2007.  Available at: 
http://www.bls.gov/ncs/ect/sp/ecsuptc4.pdf

 OPM, 2008.  Salary Table 2008-DCM.  Available at
http://www.opm.gov/oca/08tables/pdf/dcb_h.pdf

 A component is a chemical as identified by its Chemical Abstract
Service (CAS) number. An ingredient may be one component or a blend of
multiple components.

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