              Supporting Statement for a Request for OMB Review 
                       under the Paperwork Reduction Act
                                       
                      PART A OF THE SUPPORTING STATEMENT
                                       
A.1	IDENTIFICATION OF THE INFORMATION COLLECTION

A.1.a	Title of the Information Collection  
      
      EPA's Design for the Environment (DfE) Logo Redesign Consultations
      
      ICR Numbers:   EPA ICR No. 2487.01	OMB Control No. 2070-NEW
      
A.1.b	Short Characterization / Abstract

      This new information collection request (ICR) is to address the consultation process that would assist the U.S. Environmental Protection Agency (EPA) with the selection of a revised logo and messaging for its Design for the Environment (DfE) Program. A key goal of the Office of Pollution Prevention and Toxics (OPPT)'s DfE Program is to work with businesses to voluntarily incorporate safer chemicals and other health and environmental considerations into the design of their products and processes. To achieve this goal, EPA relies on outreach activities and information dissemination to industry participants and the public, as well as non-governmental organizations, other federal agencies, and state and local governments.

            Through its DfE Safer Product Labeling Program, EPA has recognized more than 2,500 products that meet the Agency's stringent human health and environmental criteria. Effective outreach and communications to businesses and the public are vital to the program's success.

            DfE's logo has remained unchanged since the program began in 1992 and does not fully and effectively represent DfE's mission to advance chemical-based products that are safer for people and the environment. A redesigned logo and messaging are needed to enhance communications and for the program to reach its potential. It is important for the DfE redesign effort to be informed by consumers, manufacturing partners, retailers, and other key audiences.

            DfE's logo redesign and accompanying communication and outreach efforts could: 
   * better convey the program's scientific expertise and the human health and environmental benefits of using safer products, 
   * increase consumer recognition of safer products carrying the redesigned DfE logo,
   * encourage businesses to participate in the DfE Program, and
   * further drive innovation and the development of safer chemical products that protect human health and the environment.
      
            This ICR would enable DfE to conduct consumer focus groups, a consumer online survey to test selected redesigned logo concepts and messaging for clarity, relevance, and appeal, and post-launch consumer online surveys to gauge consumer recognition of the new logo.

A.2	NEED FOR AND USE OF THE COLLECTION

	A.2.a	Need/Authority for the Collection

      Authority for the DfE Program derives from section 6604(b)(5) of the Pollution Prevention Act (PPA), 42 U.S.C. 13103(b)(5) (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 DfE Program. 

      Testing of DfE's logo by consumer focus groups and consumer online surveys will help ensure that the logo effectively communicates the Agency's missions under the PPA and TSCA. A logo that is clear and signals a focus on human health and the environment will increase demand for and encourage the development of safer chemical-based products, to the benefit of consumers, manufacturing partners, retailers, other stakeholders, and the environment. 

      DfE has carefully tailored this ICR to ensure that it only asks for information essential to testing the qualities of the selected redesigned logo concepts.
  
	A.2.b	Practical Utility/Users of the Data

      The information to be collected by the DfE Program is not designed or intended to support regulatory decision-making by EPA. EPA will use the information collected in these consultations to design or verify that a new logo:  (1) better convey the program's scientific expertise and the human health and environmental benefits of using safer products, (2) increase consumer recognition of safer products carrying the redesigned DfE logo, (3) encourage businesses to participate in the DfE Program, and (4) further drive innovation and the development of safer chemical products that protect human health and the environment.


A.3	NON-DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA

	A.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 DfE Program is unique and is not duplicative of previous information collection requests

	A.3.b	Public Notice Required Prior to ICR Submission to OMB

      In proposing to renew this ICR, EPA provided a 60-day public notice and comment period that ended on September 23, 2013 (78 FR 44560, July 24, 2013).  EPA received two comments during the 60-day public notice and comment period, which are characterized below.  
      
      In general the comments addressed the necessity of the proposed ICR and logo redesign. One commenter expressed support for the ICR and for redesigning the logo.  The commenter cited the value of public feedback as well as the potential for DfE to increase the clarity and conviction of the Safer Product Labeling Program's mission through the logo redesign.  These comments are consistent with EPA's assessment of the need for information collection and a redesigned logo, described in Section A.2.a.

      Another commenter stated that the ICR and the redesigned logo were not necessary and not a good use of taxpayer money.  As stated in Section A.2.a, there are expected benefits of this ICR for consumers, businesses, and the environment through the design of safer chemical-based products resulting from the use of an effective logo.
      
      The comments in their entirety and EPA's response to these comments are included in Attachment G.  

	A.3.c	Consultations

      The Agency has received input from its diverse group of DfE stakeholders regarding its logo redesign. These stakeholders include chemical manufacturers, product manufacturers, non-governmental organizations, government agencies, academics, and retailers. On May 21, 2013, DfE hosted a webinar with stakeholders to discuss the logo redesign process. These consultations have informed the questions included in the focus group screening questionnaires (Attachments B and C), the focus group moderator guide (Attachment D), the pre-launch consumer online survey to test logo design options (Attachment E), and the post-launch consumer online survey to gauge consumer recognition of the new logo (Attachment F). The same moderator guide will be used for each focus group.

      The focus group respondents and consumer online survey respondents will be members of the general population, so there are no established, organized entities with whom EPA has a purposeful relationship.  Since EPA was not able to readily identify potential respondents, consultations with the general public have not been conducted.  However, EPA personnel, with the assistance of a contractor with experience in conducting consumer market research, will design the materials for the screening questionnaires, focus groups, and consumer online surveys. The overall conclusions (descriptive and summary statistics) of the focus groups and online survey will be publicly-available. 

	A.3.d	Effects of Less Frequent Collection

      Ten consumer focus groups will be convened to test selected DfE logo design concepts. Of the ten consumer focus groups, five will be conducted with general adult consumers and five will be conducted with consumers who consider the environment when making purchasing decisions (i.e., "leaning green" consumers). Two screeners, one for each group type, will be used to identify and recruit participants for the ten groups. The same moderator guide will be used for both types of focus groups. Each consumer focus group consultation is designed to be a one-time information collection activity with consumers specifically recruited for the DfE logo redesign. The pre-launch consumer online survey to test logo design options will be a one-time information collection activity. The three post-launch consumer online surveys will be conducted to gauge recognition of the new logo. Each post-launch consumer online survey will be one-time information collection activity.  This means that once these activities end, no additional information collection activities will be required. Without these information collection mechanisms, DfE will not have the ability to test and verify consumer perceptions and understanding of the new design and if products displaying the new logo might affect the likelihood of acceptance and use. 

	A.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). 

	A.3.f	Confidentiality

      EPA does not expect that any information collected under this ICR will involve confidential business or trade secret information. The information collected will only pertain to the opinions of the respondents on the specific characteristics of the selected logo concepts as to their clarity, relevance, appeal, and likelihood of using products that display the new design. However, to the extent that any information provided during the logo testing consultations is claimed to be business confidential information, the DfE Program will handle all information claimed as such as confidential business information in accordance with Agency confidentiality procedures (see 40 CFR part 2, subpart B). The DfE Program will use information provided by consumers solely for purposes related to determining the most appropriate redesigned logo and will disclose the information only to EPA employees and EPA contractors cleared for confidential information with a specific need to know.

	A.3.g	Sensitive Questions

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


A.4	THE RESPONDENTS AND THE INFORMATION REQUESTED

	A.4.a	Respondents

      Respondents will be adult members of the general population who are consumers, including consumers who consider the environment when making purchasing decisions (i.e., "leaning green" consumers).

	A.4.b	Information Requested

   Respondents screened for focus group participation will:
   * Listen to questions, and
   * Provide answers to questions.
   Focus groups participants will:
   * Listen to directions,
   * Be presented with materials for discussion,
   * Participate in group discussions, and
   * Complete forms.
   Consumer online survey participants will:
   * Read directions,
   * Answer questions, and 
   * Submit online survey.

A.5	THE INFORMATION COLLECTED  -  AGENCY ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT

	A.5.a	Agency Activities

   EPA and its contractor will:
   * Prepare and review focus group materials,
   * Prepare and review screener questionnaires,
   * Conduct focus group screening calls,
   * Conduct focus groups,
   * Review and analyze focus group results, 
   * Prepare and review pre-launch and post-launch consumer online surveys,
   * Conduct consumer online surveys,
   * Review and analyze consumer online survey results,
   * Use focus group and pre-launch consumer online survey information to inform DfE consumer logo redesign, and
   * Use post-launch consumer online survey information to evaluate consumer recognition of redesigned logo.
	A.5.b	Collection Methodology and Management

      In collecting and analyzing the information associated with this ICR, EPA and its contractor will use a telephone system and personal computers. The contractor will employ transcription to collect information from focus group participants. The transcriptions will be kept on file but will not be distributed publicly. Personal computers will be used for the consumer online surveys. Detailed information on survey resources is outlined in Part B of this Supporting Statement.

	A.5.c	Small Entity Flexibility

      No information will be collected from small entities during this information collection.

	A.5.d	Collection Schedule

      Screening calls and focus groups will be scheduled shortly after this ICR is approved. The consumer online survey to test logo design options will be distributed shortly after this ICR is approved. The consumer online survey to gauge recognition of the new logo will be distributed six to 12 months after the redesigned logo has been launched by EPA, and then two additional times during the course of the three-year approval period.


A.6	ESTIMATING THE BURDEN AND COST OF THE COLLECTION

	A.6.a	Estimating Respondent Burden and Costs

      Table 1 presents the estimated respondent burden hours and costs associated with the information collection activities under this ICR. EPA based its burden estimates on its focus groups and online surveys conducted for similar programs.

      The average respondent burden is estimated to be 10 minutes or 0.17 hours for respondents screened for the focus groups. This estimate is based on the length of time needed to complete a screening questionnaire. There will be two sets of screening questions used for this information collection, one for general adult consumers and one for adult consumers that lean towards the purchase and use of green products. For each focus group, 90 people will be screened using the respective questionnaire. A total of 900 people will be screened as part of this information collection. There is an estimated total respondent burden of 150 hours for the ten focus group screenings.

      The average respondent burden is estimated to be 2 hours for focus group participants. This estimate is based on the length of time designated for each focus group session. There will be ten focus groups conducted during this information collection, five for general adult consumers and five for adult consumers that lean towards the purchase and use of green products. Each focus group will have 9 participants. A total of 90 people will participate in the focus groups conducted as part of this information collection. For the ten focus groups, there is an estimated total respondent burden of 180 hours.

      The average respondent burden is estimated to be 20 minutes or 0.33 hours for the pre-launch consumer online survey to test logo design options. This estimate is based on the length of time needed to complete the pre-launch consumer online survey. There will be one pre-launch survey administered as part of this information collection. The same survey will be administered to all respondents. A total of 2,000 people will complete the survey as part of this information collection. For the pre-launch consumer online survey, there is an estimated total respondent burden of 667 hours.

      The average respondent burden is estimated to be 10 minutes or 0.17 hours for the post-launch consumer online survey to gauge consumer recognition of the new logo. This estimate is based on the length of time needed to complete the post-launch consumer online survey. The will be three iterations of the post-launch consumer online survey conducted during this information collection, each of which will use the same set of questions. The same survey will be administered to all respondents. Each post-launch consumer online survey will have 2,000 respondents. A total of 6,000 people will complete the post-launch consumer online survey as part of this information collection. For the three post-launch consumer online surveys, there is an estimated total respondent burden of 1,000 hours.

      To value the respondents' time, data released on June 12, 2013 from the Bureau of Labor Statistics (BLS) Employer Costs for Employee Compensation  -  March 2013 was used. The average wage for a civilian worker, which includes private industry and state and local government workers, averaged $21.50 per hour worked in March 2013; benefits for a civilian worker averaged $9.59. The average loaded wage for a civilian worker, and therefore the estimate of the cost of a participant's time, is $31.09 per hour. No capital or operating and maintenance costs are incurred by respondents under this ICR.

      Focus group participants are typically provided with an incentive  -  usually a cash or check payment at the close of their research session. The total incentive/travel reimbursement offered to each consumer participant will be $100 for 2 hours. Survey participants receive an incentive for participating in the panel. They receive points for completion of the survey, and the points can be redeemed for cash or prizes. Survey participants will receive an estimated equivalent of $3 to $5 for completing this survey.

Table 1. Estimated Burden and Costs to Respondents
                              Collection Activity
                             Number of Respondents
                             Frequency of Response
                              Hours Per Response
                              Total Burden Hours
                                 Total Burden
                                      ($)
Screening for Consumer Focus Groups
                                      900
                                       1
                                     0.17
                                      150
                                                                      $4,663.50
Consumer Focus Group Interviews
                                      90
                                       1
                                       2
                                      180
                                                                      $5,596.20
Pre-Launch Consumer Online Survey
                                     2000
                                       1
                                     0.33
                                      667
                                                                     $20,726.67
Post-Launch Consumer Online Survey
                                     6000
                                       1
                                     0.17
                                     1000
                                                                     $31,090.00
Total
                                     8,990
                                      --
                                      --
                                     1,997
                                                                     $62,076.37
[1] No capital or operating and maintenance costs are incurred by respondents under this ICR.
[2] Hourly rate of $31.09 derived from Employer costs per hour worked for employee compensation and costs as a percent of total compensation: Civilian workers, by major occupational and industry group, March 2013. U.S. Department of Labor, Bureau of Labor Statistics. Available at http://www.bls.gov/news.release/archives/ecec_06122013.pdf.


	A.6.b	Estimating Agency Burden and Costs

      Table 2 presents the estimated Agency burden hours and costs associated with the information collection activities under this ICR. EPA based its burden estimates on its focus groups conducted for similar programs.

      The cost to prepare, organize and conduct the ten focus groups is $35,750. This fixed amount includes facility rental, recruiting costs, and transcription. This fixed amount also includes the $100 honorarium paid to each of the 90 focus group participants. Although the contractor will make the focus group screening calls, prepare the focus group materials, and conduct the focus groups, Agency staff will need to review the focus group materials, the screener questionnaires, and the focus group results. EPA expects that review of the focus group materials will take about 2.5 hours (0.5 managerial, 2 technical). Reviewing the focus group screening questionnaires will take about 2.5 hours (0.5 managerial, 2 technical). Reviewing the focus group results will take about 25 hours (5 managerial, 20 technical).

      The cost to prepare and conduct the four consumer online surveys is $31,500. This fixed cost includes the $12,000 cost to prepare and conduct the pre-launch consumer online survey and the $19,500 cost to prepare and conduct the three post-launch consumer online surveys. This fixed amount includes questionnaire development, programming, online fielding and results reporting. Although the contractor will prepare and conduct the consumer online surveys, Agency staff will need to review the survey content, design, and results. EPA expects that review of the survey content and design will take about 5 hours (1 managerial, 4 technical). Reviewing survey results will take about 10 hours (2 managerial, 8 technical).

      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 2013. The average hourly labor rate for managerial staff is estimated as the rate for a GS-13 Step 5 employee and the average hourly labor rate for technical staff is estimated as the rate for a GS-10 Step 10 employee. 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 $77 for managerial staff and $57 for technical staff. The Agency expects most activities related to this ICR to be performed by managerial staff (20 percent) and technical staff (80 percent). 


Table 2. Estimated Burden and Costs to Agency
                              Collection Activity
                               EPA Burden Hours
                                   EPA Costs

                                  Mgr.
$77/Hr
                               Technical
$57/Hr
                                Total EPA Hours
                                Contractor Cost
                                   EPA Cost
Consumer Focus Groups
Prepare focus group materials
                                                                            0.5
                                                                              2
                                                                            2.5
        $35,750 for ten focus groups (includes payment to participants)
                                                                        $152.50
Prepare screener questionnaires
                                                                            0.5
                                                                              2
                                                                            2.5
                                                                               
                                                                        $152.50
Organize and conduct focus groups
                                                                             --
                                                                             --
                                                                              0
                                                                               
                                                                          $0.00
Review focus group results
                                                                              5
                                                                             20
                                                                             25
                                                                               
                                                                      $1,525.00
Subtotal
                                                                              6
                                                                             24
                                                                             30
                                                                        $35,750
                                                                      $1,830.00
Consumer Online Surveys
Prepare consumer online surveys
                                                                              1
                                                                              4
                                                                              5
                   $31,500 for four consumer online surveys
                                                                        $305.00
Review consumer online survey results
                                                                              2
                                                                              8
                                                                             10
                                                                               
                                                                        $610.00
Subtotal
                                                                              3
                                                                             12
                                                                             15
                                                                        $31,500
                                                                        $915.00
Total
                                                                              9
                                                                             36
                                                                             45
                                                                        $67,250
                                                                      $2,745.00
[1] Contractor cost includes facility rental, recruiting, honorariums, and transcription.
[2] No capital or operating and maintenance costs are incurred by the Agency under this ICR.
[3] Hourly rates for Agency staff derived from Salary Table 2013-DCB, Washington-Baltimore-Northern Virginia, DC-MD-VA-WV-PA. Office of Personnel Management. Available at http://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/2013/general-schedule/dcb_h.pdf.

	A.6.c	Bottom Line Burden Hours and Cost Tables

      a.	Respondent Tally

      Table 3 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. However, the ten focus groups, their respective screening calls, the pre-launch consumer online survey, and the three post-launch consumer online surveys will only be conducted once over the three-year period.

Table 3. Total Annual Estimated Respondent Burden and Cost Summary
                            Total # of Respondents
                             Average Burden Hours
                                  Annual Cost
                                     8,990
                                     1,997
                                  $62,076.37

      b.	Agency Tally

      Table 4 below summarizes the total annual estimated Agency burden and cost (including contractor cost). These estimates represent the average burden in any given year over the three years covered by this ICR. However, the ten focus groups, their respective screening calls, and the consumer online surveys will only be conducted once over the three-year period.
							
Table 4. Total Annual Estimated Agency Burden and Cost Summary
                                 Burden Hours
                                  Annual Cost
                                      45
                                    $69,995

	A.6.d	Reasons for Change in Burden

      Since this is a new ICR, change in burden is not applicable.

	A.6.e	Burden Statement

      The annual public burden for this collection of information is estimated to be 0.17 hours per response for screened respondents, 2 hours for respondents that participate in the focus groups, 0.33 hours per response for pre-launch consumer online survey respondents, and 0.17 hours per response for post-launch online survey respondents. Burden is defined in 5 CFR 1320.3(b).  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-2013-0403, which is available for online viewing at www.regulations.gov, or in-person 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., N.W., 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.

      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-2013-0403 and OMB Control No. 2070-NEW, to (1) EPA online using www.regulations.gov (our preferred method), or by mail to: Pollution Prevention and Toxics Docket, Environmental Protection Agency Docket Center (EPA/DC), Mailcode: 28221T, 1200 Pennsylvania Ave., N.W., Washington, DC 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, N.W., Washington, DC 20503.
                      PART B OF THE SUPPORTING STATEMENT
B.1	RESPONDENT UNIVERSE AND SAMPLING METHODS
	
	EPA proposes the use of an online (i.e., web-based) sampling approach as a complement to the consumer focus groups described in Part A of the supporting statement. The pre-launch consumer online survey is included as Attachment E of the supporting statement; the post-launch consumer online survey is included as Attachment F of the supporting statement. The online survey will seek a panel-based (non-probability) sample of 2,000 U.S. adults ages 18 and older that has a reasonable degree of diversity in key demographic characteristics such as age, gender, education, and race/ethnicity. The sample of individuals invited to participate in the survey will be balanced to the U.S. population, based on demographic information (age, gender, educational attainment, geographic region, etc.) collected by the U.S. Census Bureau through the Current Population Survey. Once the data are collected, the sample is weighted on the same demographic variables to adjust the sample to U.S. adult population and correct any potential differential responses by demographic groups. While the results will be weighted to the U.S. adult population, EPA does not intend to generalize the results to the overall population or produce precise estimates of population parameters using the surveys.
	
      To support implementation of the consumer online surveys, EPA would retain Ipsos, a vendor that maintains a preexisting representative national panel. 

      The overall sampling frame for the online consumer surveys is the panel of individuals previously recruited by Ipsos (i.e., the Ipsos Online Panel) to participate in online surveys. The Ipsos Online Panel is an actively managed research access panel that uses multi-source recruitment to maintain a representative base of respondents. It includes individuals who have volunteered to take part in market research and is extensively profiled to efficiently target respondents. 

      Ipsos employs a survey router (brand name is Cortex) to manage a sample so that it will be representative of a population. Ipsos follows best-in-class principles to measure and report any selection bias that arises from the use of a router:
      
   oo Designated team to manage and monitor the router, made up of Ipsos sampling and methodology experts 
   oo Router management team has final authority over which studies are in the router and any prioritization decisions 
   oo Restricted impact of highly-targeted studies 
   oo Random and priority reallocation is balanced 
   oo Respondents allowed to opt-out of the screening process with no penalty 
   oo Diverse, large number of studies maintained in the router 
   oo Limited number of custom screening questions allowed 
   oo All router studies are reviewed by the router team and removed from the router if necessary 
   oo Key metrics monitored multiple times daily to identify potential performance issues 
   oo Supplier traffic is monitored daily to ensure consistency 
   oo Representativeness and consistency of the router population to the general population is monitored 
      Panel management protocols include a series of legitimacy checks, including name/address matching using external databases, digital fingerprinting, and TrueSample. Ipsos utilizes inbuilt criteria such as the exclusion of individuals who repeatedly fail to respond to survey invitations, as well as the use of algorithms to screen out participants who exhibit undesirable survey behavior (e.g., inconsistent response, straight-lining, speeding through, etc.).

      In addition, steps are taken to ensure that panel members are not overburdened with survey requests. The primary sampling rule is to assign no more than one survey per week to members. This level of survey frequency helps to keep panelists engaged as part of the panel. To minimize panel attrition, surveys are usually kept short (under 20 minutes in length). For surveys requiring 16 or more survey minutes, survey participation is rewarded with points that can be redeemed for cash or prizes. The survey we are proposing will not exceed 20 minutes, and participants will be offered a small incentive of points with a cash value of less than $1. We anticipate a 75% response rate for this survey from among invited participants in the panel.

B.2	PROCEDURES FOR THE COLLECTION OF INFORMATION

      The pre-launch consumer online survey includes questions about potential program names and visual designs. It will be administered to online panels to test selected logo concepts for clarity, relevance, appeal, and likelihood of use. 

      The post-launch consumer online survey includes questions about familiarity with the DfE labeling program and logo recognition.

      Ipsos conducts all of its online data collection via websites. Through the sampling process, panelists are pre-selected to answer a certain survey; the surveys are not "open access" (i.e., respondents are not self-selected), and respondents do not know the survey content. Panelists receive an invitation email with the following information: 

   oo Survey information (end date, survey number, survey duration, number of incentive points)
   oo A unique URL that provides access to the questionnaire 
   oo Physical address for Ipsos 
   oo Member support email address 
   oo Link to privacy policy 
   oo Opt-out information 
   To ensure high quality data, data submitted through the consumer online surveys will be subjected to statistical validation techniques, such as disallowing out-of-range values.  
	
	All data collection and analysis will be performed in compliance with OMB, Privacy Act, and Protection of Human Subjects requirements.
	
	
Confidentiality, Privacy and Opt-In Details:
      Participation in research is voluntary at the time respondents are asked to join the panel, at the time they are asked to participate in any particular survey, and at the time they answer any given question in a survey. Panelists are not coerced to participate in any research and are not removed from the panel as a result of failure to participate in any particular survey project or program of studies. Panelists have the option to `opt-out' of the panel at any time by notifying Ipsos. Ipsos maintains a toll-free phone number and its own call-center panel management facility to receive requests for information and action from panelists.

      Survey responses are confidential, with identifying information never revealed without respondent approval. When surveys are assigned to panel members, they receive notice in their password protected e-mail account that the survey is available for completion. Surveys are self-administered and accessible any time of day for a designated period. Participants can complete a survey only once. All panelists, when joining the panel, are given a copy of the Privacy and Terms of Use Policy. The privacy terms are also available electronically at all times to panelists via the panel member website. 

B.3	METHODS TO MAXIMIZE RESPONSE RATES AND DEAL WITH NON-RESPONSE
	
	Ipsos' methodology for maximizing response rates includes the following:
	
   oo Targeted recruitment through various "wide net" methodologies (e.g., email campaigns, affiliate networks, banner ads, text ads, search engine, co-registration, offline-to-online, specialized websites) 
   oo Use of a point system to incentivize panelists, along with sweepstakes draws. Points systems are recognized as being the best in class in online market research, as they are seen as a neutral system which does not skew the participation of specific groups of people
   oo Customized incentives and materials for recruiting special targets such as mothers of babies, age group 55+, etc., to be used only as needed 
   oo Continuously testing new recruitment sources and methods 
   oo Use of an internal data quality process that incorporates data quality checks at the survey level to reduce or eliminate random responding, illogical or inconsistent responding, overuse of item non-response, and too rapid survey completion.
      We do not anticipate challenges with non-response, given the broadly defined eligibility criteria for the survey. However, in the event of non-response challenges, we will send reminders to non-respondents, and monitor and correct any potential non-response biases.  

	Survey results will not be used for evaluation purposes, or to make policy or regulatory decisions. We believe a non-probability sample is adequate for EPA's purpose of supporting communications testing and consumer outreach and education efforts. 
B.4	TEST OF PROCEDURES OR METHODS
	
	Before the online surveys are implemented, a contractor will pilot test the instrument(s) and method of data collection. Lessons from the pilot test will be identified, and changes as necessary will be incorporated into the instrument and method. All pilot tests will involve no more than nine individuals.	
	
B.5	INDIVIDUALS CONSULTED ON STATISTICAL ASPECTS AND INDIVIDUALS COLLECTING AND/OR ANALYZING DATA
	
      Alan Roshwalb, PhD, will serve as the Sampling Statistician for this project. Dr. Roshwalb is a Senior Vice President at Ipsos and joined the company in 1995. He will work with the Deputy Statistician in creating the analysis plan and executing the data analyses. Dr. Roshwalb has almost twenty years of research experience. While with Ipsos, he has served as a survey program design consultant, lead data analyst, sampling consultant, and project manager on many projects for clients such as the FDA, the Army Surgeon General, the United States Postal Service (USPS), the Federal Trade Commission, the Social Security Administration, the U.S. Patent and Trademark Office (USPTO), the Consumer Product Safety Commission, the National Institutes of Health, and Kaiser Permanente. Dr. Roshwalb is a seasoned expert in the design of surveys and sampling theory and provides consultation on quality management issues including the development of performance standards to a variety of service industry clients. He has taught statistics and applied quantitative methods, and he has authored professional papers on statistical and research methodology for social science, marketing, accounting, and management periodicals such as The Accounting Review and The Journal of Business and Economic Statistics. Dr. Roshwalb can be reached at 202-420-2029.
	
 

                    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-2013-0403. These attachments are available for online viewing at www.regulations.gov or otherwise accessed as described in section 6(g) of the supporting statement.

Attachment A:	42 USC 13103 - Pollution Prevention Act Section 6604. Also available 
            online at the US House of Representatives' Office of the Law Revision 
            Counsel's US Code website
	
Attachment B:	Screening Questionnaire for "Leaning Green" Consumer Focus 
            Group

Attachment C:	Screening Questionnaire for General Adult Consumer Focus Group

Attachment D:	Moderator's Guide for Consumer Focus Group Session

Attachment E:	Survey for EPA Design for the Environment (DfE) Redesign of Visual Mark:  General Adult Population Survey

Attachment F:	Survey for EPA Design for the Environment (DfE) Post-Launch Awareness Test of New Visual Mark:  General Adult Population Survey

Attachment G:	Response to Comments: EPA's Design for the Environment (DfE)  Logo Redesign Consultation

