                                 ATTACHMENT J
                     Detailed Burden and Cost Calculations

Wage Rates

Respondents
                                 ICR Category
                                 BLS Category
                                Overall Hourly
                                     Wage
                                Fringe Benefit
                              Total Compensation
                     Overhead % of Total Compensation [c]
                                   Overhead
                              Hourly Loaded Wages
                                    Rounded
General civilian
All workers (average civilian worker) [a]
                                    $38.26
                                    $26.25
                                    $12.01
                                    $38.26 
                                      20%
                                     $7.65
                                    $45.91 
                                     $46 
Management
Management, business and financial [b]
                                    $74.94
                                    $52.01
                                    $22.93
                                    $74.94 
                                      20%
                                    $14.99
                                    $89.93 
                                     $90 
Technical
Professional and related [b]
                                    $69.80
                                    $46.57
                                    $23.23
                                    $69.80 
                                      20%
                                    $13.96
                                    $83.76 
                                     $84 
Clerical
Office and administrative support [b]
                                    $29.87
                                    $20.39
                                     $9.48
                                    $29.87 
                                      20%
                                     $5.97
                                    $35.84 
                                     $36 
[a] Source: Bureau of Labor Statistics, 2020 (https://www.bls.gov/news.release/pdf/ecec.pdf)
[b] Source: Bureau of Labor Statistics, 2020 (https://www.bls.gov/web/ecec/ecsuphst.pdf) 
[c] An overhead rate of 20% is used based on assumptions in Handbook on Valuing Changes in Time Use Induced by Regulatory Requirements and Other U.S. EPA Actions (EPA 2020).
Note: the loaded wage is only used when considering burden for technical materials, thereby excluding the POY Awards and redesign consultations.

Agency
                                 ICR Category
                                 OPM Category
                                Overall Hourly
                              Loading Factor [a]
                                 Loaded Wages
                                    Rounded
Management
GS-13 Step 5
                                    $56.31
                                     1.639
                                    $92.29
                                      $92
Technical
GS-10 Step 10
                                    $41.25
                                     1.639
                                    $67.61
                                      $68
Clerical
GS-5 Step 1
                                    $19.01
                                     1.639
                                    $31.16
                                      $31
Source: Office of Personnel Management, 2021 (https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/21Tables/html/DCB_h.aspx)  
[a] Source: Falk, J. 2012. "Comparing Benefits and Total Compensation in the Federal Government and the Private Sector." Congressional Budget Office Working Paper Series. (https://www.cbo.gov/sites/default/files/112th-congress-2011-2012/workingpaper/2012-04fedbenefitswp0.pdf) 

IC #1: Safer Choice product recognition program applications

Respondents
Collection Activity
                        Hours and Costs Per Respondent
                             Total Hours and Costs

                                     Mgr.
                                       
                                     Tech.
                                       
                                     Cler.
                                       
                               Response Hours/Yr
                                Labor Cost/Year
                                    Capital
                                     Cost
                                O & M Cost*
                              Number of Respon.**
                                Total Hours/Yr
                                 Total Cost/Yr
Partnership Agreements
Review program information 
                                                                              1
                                                                              1
                                                                              0
                                                                              2
                                                                        $174.00
                                                                            $0 
                                                                            $0 
                                                                             44
                                                                             88
                                                                        $7,656 
Fill out and submit third-party information request form
                                                                              0
                                                                              5
                                                                              1
                                                                              6
                                                                        $456.00
                                                                            $0 
                                                                            $0 
                                                                             44
                                                                            264
                                                                       $20,064 
Establish agreement with third-party profiler
                                                                              1
                                                                              1
                                                                              1
                                                                              3
                                                                        $210.00
                                                                            $0 
                                                                       $12,400 
                                                                             44
                                                                            132
                                                                      $554,840 
Submit summary report to Safer Choice
                                                                              1
                                                                              1
                                                                              0
                                                                              2
                                                                        $174.00
                                                                            $0 
                                                                            $0 
                                                                             44
                                                                             88
                                                                        $7,656 
Negotiate / establish Partnership Agreement w/ Safer Choice
                                                                              1
                                                                              2
                                                                              0
                                                                              3
                                                                        $258.00
                                                                            $0 
                                                                            $0 
                                                                             44
                                                                            132
                                                                       $11,352 
Subtotal
                                                                              4
                                                                             10
                                                                              2
                                                                             16
                                                                      $1,272.00
                                                                            $0 
                                                                       $12,400 
                                                                             44
                                                                            704
                                                                      $601,568 
Renewals and Audits
Renew partnership, with no changes needed
                                                                              0
                                                                              3
                                                                              1
                                                                              4
                                                                        $288.00
                                                                            $0 
                                                                            $0 
                                                                             36
                                                                            144
                                                                       $10,368 
Desk audit
                                                                              0
                                                                              2
                                                                              2
                                                                              4
                                                                        $240.00
                                                                            $0 
                                                                            $0 
                                                                             24
                                                                             96
                                                                        $5,760 
Site audit
                                                                              0
                                                                              2
                                                                              1
                                                                              3
                                                                        $204.00
                                                                            $0 
                                                                            $0 
                                                                             12
                                                                             36
                                                                        $2,448 
Subtotal
                                                                              0
                                                                              7
                                                                              4
                                                                             11
                                                                          $732 
                                                                            $0 
                                                                            $0 
                                                                             36
                                                                            276
                                                                       $18,576 
Adding Private Label Partners and Products
Review program information
                                                                              1
                                                                              1
                                                                              0
                                                                              2
                                                                        $174.00
                                                                            $0 
                                                                            $0 
                                                                             77
                                                                            154
                                                                       $13,398 
Fill out and submit online Private Label submission
                                                                              0
                                                                            4.5
                                                                            1.5
                                                                              6
                                                                        $432.00
                                                                            $0 
                                                                            $0 
                                                                             77
                                                                            462
                                                                       $33,264 
Subtotal
                                                                              1
                                                                            5.5
                                                                            1.5
                                                                              8
                                                                          $606 
                                                                            $0 
                                                                            $0 
                                                                             77
                                                                            616
                                                                       $46,662 
TOTAL
 
 
 
 
 
 
 
                                                                            157
                                                                          1,596
                                                                      $666,806 
* The cost for third-party profiler review and verification assumes that the typical application submitted by a cleaning product manufacturer will contain four products, each with 2 ingredients ($650 each), 1 proprietary ingredient ($1,300), and a $500 administrative fee. The total cost per product is $3,100. The total will be $12,400 per company per application.
**This column reports the number of annual respondents after accounting for the partnership renewal process.  Assumes that one in ten formulators over the three-year period will need to make changes to their formulations and go through a new partnership process which includes same collection steps.  On an annual basis, this translates to 4 product formulators (for a total of 44 partnership agreements).  Also assumes that about 33% of the remaining product formulators will be subject to site audits each year (i.e., 12) and that about 66% (i.e., 24) will be subject to desk audits each year. Assumes that 77 partners will fill out Private Label submissions based on historical data.

Agency
Collection Activity
                        Hours and Costs Per Respondent
                             Total Hours and Costs

                                 Mgr. Hours/Yr
                                Tech. Hours/Yr
                                Agency Hours/Yr
                                Labor Cost/Year
                            Capital / Startup Cost
                                O & M Cost
                              Number of Respon.*
                                Total Hours/Yr
                                 Total Cost/Yr










Cleaning and Non-Cleaning Products
Review program application forms
                                                                              0
                                                                              1
                                                                              1
                                                                           $68 
                                                                            $0 
                                                                            $0 
                                                                             44
                                                                             44
                                                                        $2,992 
Review third-party profiler summary
                                                                              0
                                                                              5
                                                                              5
                                                                          $340 
                                                                            $0 
                                                                            $0 
                                                                             44
                                                                            220
                                                                       $14,960 
Negotiate / establish Partnership Agreement with formulator
                                                                              1
                                                                              2
                                                                              3
                                                                          $228 
                                                                            $0 
                                                                            $0 
                                                                             44
                                                                            132
                                                                       $10,032 
Review partnership renewal, with no changes needed
                                                                              1
                                                                              1
                                                                              2
                                                                          $160 
                                                                            $0 
                                                                            $0 
                                                                             36
                                                                             72
                                                                        $5,760 
Review audit summaries
                                                                              0
                                                                              1
                                                                              1
                                                                           $68 
                                                                            $0 
                                                                            $0 
                                                                             36
                                                                             36
                                                                        $2,448 
Subtotal
                                                                              2
                                                                             10
                                                                             12
                                                                          $864 
                                                                            $0 
                                                                            $0 
                                                                             80
                                                                            504
                                                                       $36,192 
Adding Private Label Partners and Products
Review Private Label submissions
                                                                              0
                                                                              2
                                                                              2
                                                                          $136 
                                                                            $0 
                                                                            $0 
                                                                             77
                                                                            154
                                                                       $10,472 
Subtotal
                                                                              0
                                                                              2
                                                                              2
                                                                          $136 
                                                                            $0 
                                                                            $0 
                                                                             77
                                                                            154
                                                                        $10,472
TOTAL
                                       
                                                                            157
                                                                            658
                                                                       $46,664 
*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. 4, for a total of 44 annually. Assumes that 77 partners will fill out Private Label submissions based on historical data.


IC #2: Safer Choice label consultations

Respondents
Collection Activity
                             Number of Respondents
                             Frequency of Response
                              Hours Per Response
                              Total Burden Hours
                                  Total Cost
Screening for Consumer Focus Groups
                                      300
                                       1
                                     0.17
                                      51
                                                                        $2,346 
Consumer Focus Group Interviews
                                      30
                                       1
                                       2
                                      60
                                                                        $2,760 
Consumer Online Survey
                                     2,000
                                       1
                                      0.5
                                     1,000
                                                                       $46,000 
TOTAL
                                     2,330
                                      --
                                      --
                                     1,111
                                                                       $51,106 
Note: No capital or operating and maintenance costs are incurred by respondents under this component of the ICR.

Agency
                              Collection Activity
                               EPA Burden Hours
                                   EPA Costs

                                  Mgr. Hours
                                       
                                  Tech. Hours
                                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 
                                                                          $182 
Prepare screener questionnaires
                                                                            0.5
                                                                              2
                                                                            2.5

                                                                          $182 
Organize and conduct focus groups
                                                                              0
                                                                              0
                                                                              0

                                                                            $0 
Review focus group results
                                                                              5
                                                                             20
                                                                             25

                                                                        $1,820 
Subtotal
                                                                              6
                                                                             24
                                                                             30
                                                                       $35,750 
                                                                        $2,184 
Consumer Online Surveys
Prepare consumer online surveys
                                                                              1
                                                                              4
                                                                              5
                   $23,625 for four consumer online surveys
                                                                          $364 
Review consumer online survey results
                                                                              2
                                                                              8
                                                                             10

                                                                          $728 
Subtotal
                                                                              3
                                                                             12
                                                                             15
                                                                       $23,625 
                                                                        $1,092 
TOTAL
                                                                              9
                                                                             36
                                                                             45
                                                                       $59,375 
                                                                        $3,276 
Note: Due to the contractor costs, these figures represent the total agency burden across the three-year period of the ICR.
Note: No capital or operating and maintenance costs are incurred by the Agency under this component of the ICR.
* Contractor cost for consumer focus groups includes facility rental, recruiting, honorariums, transcription, and reimbursement to focus group participants for their travel and time (assumed $100 per participant). Contractor cost for consumer online surveys includes questionnaire development, programming, online fielding and results reporting.

IC #3: Safer Choice Partner of the Year Awards program

Respondents
                              Collection Activity
                           Estimated # of Applicants
                        Estimated Response Time (Hours)
                             Total Burden (Hours)
                                  Total Cost
                                       
                                       
                                     Mgr.
                                     Tech.
                                     Cler.
                                     Mgr.
                                     Tech.
                                     Cler.
                                     Total
                                       
Formulators/Product Manufacturers
Review application and program information
                                       
                                       0
                                       1
                                       0
                                       0
                                      19
                                       0
                                      19
                                    $1,326 
Obtain senior approval
                                       
                                       1
                                       1
                                       1
                                      19
                                      19
                                      19
                                      57
                                    $3,318 
Complete and submit package
                                       
                                       0
                                      10
                                       1
                                       0
                                      190
                                      19
                                      209
                                   $13,830 
Subtotal
                                      19
                                       1
                                      12
                                       2
                                      19
                                      228
                                      38
                                      285
                                  $18,473.32
Innovators
Review application and program information
                                       
                                       0
                                       1
                                       0
                                       0
                                       5
                                       0
                                       5
                                     $349 
Obtain senior approval
                                       
                                       1
                                       1
                                       1
                                       5
                                       5
                                       5
                                      15
                                     $873 
Complete and submit package[1]
                                       
                                       0
                                      10
                                       1
                                       0
                                      50
                                       5
                                      55
                                    $3,639 
Subtotal
                                       5
                                       1
                                      12
                                       2
                                       5
                                      60
                                      10
                                      75
                                   $4,861.40
Retailers
Review application and program information
                                       
                                       0
                                       1
                                       0
                                       0
                                       3
                                       0
                                       3
                                     $209 
Obtain senior approval
                                       
                                       1
                                       1
                                       1
                                       3
                                       3
                                       3
                                       9
                                     $524 
Complete and submit package
                                       
                                       0
                                      10
                                       1
                                       0
                                      30
                                       3
                                      33
                                    $2,184 
Subtotal
                                       3
                                       1
                                      12
                                       2
                                       3
                                      36
                                       6
                                      45
                                   $2,916.84
Supporters
Review application and program information
                                       
                                       0
                                       1
                                       0
                                       0
                                       6
                                       0
                                       6
                                     $419 
Obtain senior approval
                                       
                                       1
                                       1
                                       1
                                       6
                                       6
                                       6
                                      18
                                    $1,048 
Complete and submit package
                                       
                                       0
                                      10
                                       1
                                       0
                                      60
                                       6
                                      66
                                    $4,367 
Subtotal
                                       6
                                       1
                                      12
                                       2
                                       6
                                      72
                                      12
                                      90
                                   $5,833.68
Purchasers and Distributors
Review application and program information
                                       
                                       0
                                       1
                                       0
                                       0
                                       2
                                       0
                                       2
                                     $140 
Obtain senior approval
                                       
                                       1
                                       1
                                       1
                                       2
                                       2
                                       2
                                       6
                                     $349 
Complete and submit package
                                       
                                       0
                                      10
                                       1
                                       0
                                      20
                                       2
                                      22
                                    $1,456 
Subtotal
                                       2
                                       1
                                      12
                                       2
                                       2
                                      24
                                       4
                                      30
                                   $1,944.56
TOTAL
                                      35
                                       
                                       
                                       
                                       
                                       
                                       
                                      525
                                    $34,030
Note: All respondents are from the private sector, other than potential respondents in the "Purchasers and Distributors" and "Supporters" categories which may include local and state governments.

Agency
                                  Activities
                           Hours per Labor Category
                            Total Cost per Activity
                             Total Hours and Cost
                                       
                                  Mgr. Hours
                                  Tech. Hours
                                  Mgr. Hours
                                  Tech. Hours
                           Total Hours per Activity
                            Total Cost per Activity
Distribute forms
                                       2
                                       8
                                     $184
                                     $544
                                      10
                                     $728
Answer questions
                                       2
                                       8
                                     $184
                                     $544
                                      10
                                     $728
Record / enter forms
                                       3
                                      10
                                     $276
                                     $680
                                      13
                                     $956
Verify information; Make awards selection
                                       4
                                      13
                                     $368
                                     $884
                                      17
                                    $1,252
Notify applicants of decision
                                       1
                                       3
                                      $92
                                     $204
                                       4
                                     $296
TOTAL
                                      12
                                      42
                                    $1,104
                                    $2,856
                                      54
                                    $3,960

