Memorandum

To:		Patricia Mercer, EPA

From:		Maribelle Rodríguez and Earl Harris

Date:		September 21, 2007

Subject:	Results of Analysis 7 under Technical Directive 1 of Work
Assignment Base-25, Contract No. EP-W-07-003

The above referenced technical directive asks for a graph or chart that
shows specified information for R&D labs at commercial facilities and
Federal government research labs.  Based on conversations with you, ICF
agreed to attempt to gather information about:  (1) the number and types
of students at these sites (i.e., in paid and/or unpaid position) and
(2) how long these students normally work there.  

	Following are the results and status of our research.

I.	R&D Labs at Commercial Facilities

	ICF contacted Tom White of PHRMA regarding EPA’s data needs.  Mr.
White had submitted a comment letter to EPA on the proposed Subpart K
rule.  On September 12, 2007, Mr. White agreed to collect information
from its member companies to address EPA’s data needs as best they
could.  On September 21, Mr. White told ICF that he was unable to
collect the requested information.  He indicated that additional time is
needed and suggested a date of October 12, 2007, to provide the data.  

Please let us know if we should ask him to go ahead.  

II.	Federal Government Research Labs

	ICF reached five Federal agencies by phone to request the desired
information.  Of these, only one (National Institutes of Health) was
able to provide reliable information in a timely manner.  Another agency
(i.e., Fort Detrick, U.S. Army) agreed to provide the information for
its specific location, but has not done so yet.  The remaining three
agencies were unable to provide reliable, if any, information and do not
believe centralized data are available on students working in their
labs.  

If this assessment is accurate, the information would need to be
collected agency by agency in some cases.  In other cases, ICF may find
centralized information, as was the case for NASA and, presumably, the
Department of Energy.  EPA’s decision on whether to continue this data
collection depends, in part, on the amount of time available, as well as
the amount of data that it needs for analysis and decision-making.

	Following is a summary of ICF’s calls.

National Science Foundation (NSF). We spoke with Dr. Nirmala
Kannankutty, Senior Analyst of the NSF, about students in Federal labs. 
Her Division of Science Resources Statistics is responsible for
compiling data on the Federal workforce.  She mentioned a survey that
her colleagues used to do annually on grad students working at Federal
labs.  She agreed to look into it and get back to us on it as well as
other ideas for getting the data desired.    

She responded subsequently that she and her colleagues were unable to
provide any data.  They said that the particular data that EPA is
looking for is not available in any source that they are aware of.  The
difficulty is that EPA would like data on students specifically in
Federal labs.  She believes that data are not centralized within the
Federal government and would need to be collected on an agency-by-agency
basis, if it is available at all.  

National Institutes of Health (NIH).  ICF contacted Scott Merkle and
Debbie Cohen of the NIH.  Ms. Cohen is in the NIH Office of Intramural
Training and Education, which provides coordination of student training
programs across all the NIH Institutes.  Ms. Cohen said that NIH
compiles centralized data on students.  She said that: 

800 undergraduate students are employed during the summer.

500 doctoral students are employed on a 3-5 year basis.

3,500 post-doctoral students are employed on a 3-5 year basis.

NIH has 17,000 employees in total.  

Based on this data, ICF estimates that students represent approximately
23 to 28 percent of NIH employees.  This is a rough approximation. 

National Aeronautics and Space Administration (NASA).  ICF contacted
Mike McNeil, a NASA Environmental Engineer who commented on the proposed
rule.  Based on his past experience as a Safety and Environmental
Manager at Goddard Space Center, he estimated anecdotally that between
five and 10 percent of NASA employees are “transient” populations
from academia.  Their stay is normally a semester, but it could be
longer.  He is confident that NASA Headquarters does not collect
information on students in NASA labs.  ICF would need collect such
information on a location by location basis.

U.S. Army Medical Research Institute of Infectious Diseases at Fort
Detrick, Maryland.  ICF contacted this organization because it commented
on the proposed rule.  Its Human Resources department indicated that it
could provide information on students in its labs by September 20;
however, ICF has not heard back yet.  ICF will keep EPA informed if the
information is received.

Department of Veterans Affairs (VA), Office of Academic Affiliations. 
The VA representative said that VA does not collect information on
students who work in their labs.

Office of Personnel Management, Student Educational Employment Program. 
ICF left voicemails with this office; however our calls were not
returned.

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