SUPPORTING
STATEMENT
FOR
INFORMATION
COLLECTION
REQUEST
NUMBER
2050­
0139
"
REPORTING
AND
RECORD
KEEPING
REQUIREMENTS
UNDER
EPA'S
WASTEWISE
PROGRAM"

August
2005
CONTENTS
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
REQUEST
1(
a)
Title
and
Number
of
the
Information
Collection
Request
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1
1(
b)
Short
Characterization
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1
2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
2(
a)
Need
and
Authority
for
the
Collection
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2
2(
b)
Practical
Utility/
Users
of
the
Data
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3
3.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
3(
a)
Nonduplication
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4
3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
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4
3(
c)
Consultations
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4
3(
d)
Effects
of
Less
Frequent
Collection
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5
3(
e)
General
Guidelines
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5
3(
f)
Confidentiality
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5
3(
g)
Sensitive
Questions
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5
4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
4(
a)
Respondents
and
NAICS
Codes
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5
4(
b)
Information
Requested
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6
Partner
Registration
Form
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6
Annual
Assessment
Form
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7
Endorser
Registration
Form
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9
5.
THE
INFORMATION
COLLECTED
C
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
5(
a)
Agency
Activities
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10
Partner
Registration
Form
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10
Annual
Assessment
Form
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10
Endorser
Registration
Form
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11
5(
b)
Collection
Methodology
and
Management
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11
5(
c)
Small
Entity
Flexibility
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12
5(
d)
Collection
Schedule
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12
6.
ESTIMATING
THE
BURDEN
AND
COST
OF
COLLECTION
6(
a)
Estimating
Respondent
Burden
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12
6(
b)
Estimating
Respondent
Costs
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13
6(
c)
Estimating
Agency
Burden
and
Costs
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15
6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
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17
6(
e)
Bottom
Line
Burden
Hours
and
Costs
Tables
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17
6(
f)
Reasons
for
Change
in
Burden
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18
6(
g)
Burden
Statement
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18
EXHIBITS
Exhibit
1:
Annual
Estimated
Respondent
Burden
and
Cost
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14
Exhibit
2:
Annual
Estimated
Agency
Burden
and
Cost
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16
TABLES
Table
1:
Bottom
Line
Burden
and
Cost
to
Respondents
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17
Table
2:
Bottom
Line
Burden
and
Cost
to
EPA.
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18
ATTACHMENTS
Attachment
A:
Methodology
for
WasteWise
Multi­
Stage
Statistical
Analysis
Attachment
B:
Partner
Registration
Form
Attachment
C:
Annual
Assessment
Form
Attachment
D:
Endorser
Registration
Form
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1(
a)
Title
and
Number
of
the
Information
Collection
Request
This
Information
Collection
Request
(
ICR)
is
entitled
"
ENVIRONMENTAL
PROTECTION
AGENCY
Agency
information
collection
activities:
Proposed
collection;
Comment
Request;
Reporting
and
RECORD
KEEPING
Requirements
Under
EPA's
WasteWise
Program,"
ICR
number
2050­
0139.

1(
b)
Short
Characterization
This
submission
is
intended
to
satisfy
the
terms
of
clearance
placed
on
the
2004
ICR
approval.
The
ICR
was
approved
for
one
year,
provided
that
WasteWise
subject
its
program
evaluation
methodology
(
described
below)
to
peer
review,
and
keep
OMB
informed
of
its
peer
review
activities
during
this
time
period.
After
an
initial
meeting
with
OMB
in
March,
EPA
began
to
initiate
the
peer
review
process,
but
it
is
still
ongoing.
The
results
will
be
presented
to
OMB
as
soon
as
they
are
available.
In
the
meantime,
we
would
ask
that
an
additional
extension
be
granted,
so
that
WasteWise
can
continue
to
collect
data
from
its
partners
without
a
lapse
in
service.

The
WasteWise
program
is
an
EPA
voluntary
program
that
encourages
companies,
trade
associations,
non­
profit
organizations,
state/
local/
tribal/
federal
governments,
schools,
colleges,
and
universities
to
engage
in
waste
reduction
activities.
WasteWise
focuses
on
waste
reductionCwhich
includes
waste
prevention,
recycling
collection,
and
purchasing
or
manufacturing
recycled­
content
products.
The
program
was
developed
and
is
managed
by
EPA's
Office
of
Solid
Waste
(
OSW),
Municipal,
Industrial,
and
Special
Waste
Division
(
MISWD).
In
return
for
their
voluntary
participation
in
the
program,
WasteWise
partners
receive:

°
A
well­
developed
approach
to
program
design,
implementation,
and
documentation
of
results
that
can
be
implemented
within
a
variety
of
organizations.
°
Recognition
opportunities
through
an
annual
awards
program
and
being
featured
on
the
WasteWise
Web
site
and
in
WasteWise
and
other
EPA
publications.
°
Opportunities
to
network
with
individuals
implementing
waste
reduction
activities
in
a
variety
of
industry
sectors.
°
Helpline,
account
representative,
and
list
server
services
that
assist
with
the
identification
of
waste
reduction
opportunities,
setting
measurable
goals,
and
researching
technical
questions.
°
Access
to
a
library
and
Web
site
of
technical
assistance
resources
to
assist
in
achieving
waste
reduction
goals.

An
organization's
decision
to
participate
in
WasteWise
is
completely
voluntary.
Participation
begins
with
the
completion
and
submission
to
EPA
of
a
Partner
Registration
Form
or
Endorser
Registration
Form
(
the
WasteWise
Endorser
Program
will
be
discussed
later
in
this
document)
that
provides
EPA
with
general
organizational
information
and
the
facilities
committed
to
WasteWise.
It
is
signed
by
a
senior
official
that
has
authority
to
commit
his/
her
organization
to
the
program.

EPA
streamlined
the
registration
and
reporting
processes
as
part
of
its
2004
ICR
effort
in
an
attempt
to
decrease
the
burden
on
WasteWise
partners.
Previously,
partners
were
asked
to
register,
set
goals
within
six
months,
and
then
quantify
waste
reduction
results
each
year.
The
new
structure,
requires
partners
to
register
and
designate
priorities,
and
submit
one
other
form,
the
Annual
Assessment
Form
within
two
months.
On
this
form,
partners
submit
baseline
waste
reduction
data
and
waste
reduction
goals.
Organizations
have
broad
flexibility
in
designing
their
goals,
which
are
now
fully
incorporated
as
part
of
the
annual
assessment
process.
EPA
not
only
believes
that
by
having
partners
submit
goals
via
the
annual
page
2
assessment
form
the
related
work
will
be
less
burdensome,
but
that
this
new
structure
will
also
foster
more
effective
waste
reduction
activities.

EPA
asks
new
partners
to
spend
time
up
front
in
establishing
a
solid
foundation
for
WasteWise
initiatives
and
allots
two
months
for
partners
to
provide
baseline
data
and
goals
via
the
Annual
Assessment
Form.
The
first
year
of
membership
is
the
only
time
during
which
partners
are
asked
to
submit
baseline
data.
By
having
this
data
to
analyze,
EPA
will
be
better
suited
to
determine
how
the
program
influences
its
new
partners'
waste
reduction
achievements
by
comparing
the
baseline
data
(
measurements
from
before
initiating
WasteWise­
related
efforts)
to
what
the
partner
accomplishes
once
part
of
the
program.

Unfortunately,
there
is
not
a
way
for
WasteWise
to
obtain
baseline
waste
reduction
data
for
its
existing
partners;
consequently,
EPA
developed
a
means
to
determine
how
WasteWise
influences
its
partners'
waste
reduction
efforts.
As
part
of
the
Agency's
continued
interest
in
examining
the
success
of
the
program,
WasteWise
developed
an
econometric
methodology
that
estimates
the
amount
of
its
partners'
waste
prevention
and
recycling
achieved,
which
is
attributable
to
the
WasteWise
program
(
see
Attachment
A).
This
model,
which
relies
on
advanced
econometric
and
statistical
techniques,
will
allow
EPA
to
estimate
the
amount
of
waste
prevention
and
recycling
performed
by
existing
and
non­
reporting
partners,
formulate
estimations
on
a
material­
specific
basis
allowing
EPA
to
estimate
the
associated
global
climate
protection
benefits,
and
address
concerns
regarding
the
use
of
different
methods
by
which
partners
calculate
waste
prevention
and
recycling
achievements.

As
mentioned
above,
the
one­
year
extension
granted
to
EPA
as
a
result
of
the
2004
ICR
renewal
was
contingent
on
a
peer
review
being
completed
on
the
econometric
method
described
in
Attachment
A,
including
the
validity
of
methods
to
construct
baselines.
In
order
to
fulfill
this
condition,
EPA
has
commissioned
a
peer
review
of
the
method.

To
account
for
the
program's
activities,
WasteWise
asks
that
its
partners
report
on
their
waste
reduction
progress
by
March
31
of
each
year.
(
Established
partners
are
asked
to
submit
goals
and
waste
reduction
data
on
an
annual
basis.)
Previously,
partners
were
asked
to
submit
quantified
results
for
the
amount
of
waste
prevented
and
recycled,
the
amount
of
recycled­
content
products
purchased,
and/
or
the
increase
in
recycled
materials
used
in
the
manufacturing
process.
In
the
new,
less
burdensome
structure,
partners
are
asked
to
submit
quantified
results
via
the
Annual
Assessment
Form
in
any
of
the
following
areas:
the
amount
of
waste
prevented
and
recycled,
the
amount
of
recycled­
content
products
purchased
(
and
the
percent
of
recycled
content
in
those
products),
recycled
materials
used
in
manufacturing
processes,
revenues
from
waste
reduction
activities,
and
avoided
costs
due
to
waste
reduction
activities.
Organizations
can
easily
track
and
record
these
new
categories,
which
will
allow
partners
(
and
the
Agency)
to
assess
the
effectiveness
of
their
efforts.

At
this
time,
EPA
also
asks
partners
to
submit
revised
annual
goals.
In
the
past,
separate
from
the
annual
report,
EPA
asked
partners
to
submit
a
certain
number
of
goals
(
which
were
valid
for
three
years)
in
specific
waste
reduction
areas.
As
part
of
this
new,
more
manageable
procedure,
EPA
asks
partners
to
submit
goals
on
an
annual
basisCwhile
they
are
reviewing
their
annual
achievements.
Furthermore,
to
allow
for
more
individualized
treatment,
partners
can
set
any
number
of
goals
for
any
area
of
waste
reduction
(
e.
g.,
waste
prevention,
recycling,
buying
recycled­
content
products,
and
manufacturing
recycledcontent
products).

EPA
collects
this
information
in
hard
copy
form
or
electronically
and
then
enters
and
stores
it
in
the
WasteWise
Information
Exchange
System
database
(
WIES).
EPA
uses
the
information
collected
under
the
WasteWise
program
to
track
the
activities
of
individual
organizations
participating
in
the
program,
page
3
recognize
partner
accomplishments
in
the
three
program
areas,
and
identify
effective
waste
reduction
strategies
to
share
with
others.
Recognizing
partner
achievements
is
important
to
help
EPA
spur
other
partners
on
to
reduce
more
waste.
Sharing
effective
waste
reduction
strategies
with
others
is
a
fundamental
objective
of
the
WasteWise
program.

The
WasteWise
program
currently
has
approximately
1,400
partners.
OSW
expects
WasteWise
membership
to
increase
by
100
partners
during
each
year
of
this
ICR.
For
a
new
partner
joining
WasteWise,
the
information
collection
activities
are
estimated
on
average
to
cost
each
organization
approximately
$
2,266
in
the
first
year
and
$
2,207
for
subsequent
years.
EPA
does,
however,
expect
many
organizations
to
recognize
substantial
cost
savings,
typically
more
than
offsetting
the
above
costs,
through
the
implementation
of
their
waste
reduction
initiatives
reported
under
WasteWise.
(
EPA
evidence
suggests
that
savings
of
hundreds
of
thousands,
or
even
millions,
of
dollars
is
not
unusual
for
a
large
corporation.)

EPA
has
also
continued
the
additional
voluntary
component
to
the
WasteWise
program,
called
the
WasteWise
Endorser
Program.
Various
organizations
including
trade
associations,
membership
organizations,
and
federal/
state/
local
governments
that
become
WasteWise
endorsers
commit
to
1)
recruiting
their
members
and
other
constituents
to
become
WasteWise
partners
and
2)
to
providing
ongoing
promotional
or
technical
waste
reduction
information.
Participation
in
the
WasteWise
Endorser
Program
involves
the
submission
of
only
one
form,
the
Endorser
Registration
Form.
This
one­
page
form
provides
general
contact
information,
the
number
of
business
members
the
organization
has,
the
primary
business
sectors
represented,
and
the
activities
that
the
endorser
will
conduct.
EPA
collects
this
information
and
enters
it
into
WIES.
EPA
tracks
this
information
for
three
main
purposes:
to
establish
participation
in
the
program,
to
understand
the
activities
being
undertaken
by
each
endorser,
and
to
identify
opportunities
to
assist
them
in
their
efforts
(
e.
g.,
providing
materials
or
a
speaker).

The
WasteWise
Endorser
Program
currently
has
over
200
endorsers.
EPA
expects
membership
in
the
WasteWise
Endorser
Program
to
increase
by
25
endorsers
during
each
year
of
this
ICR.
The
information
collection
activities
will
translate
into
a
one­
time
cost
to
each
individual
organization
of
approximately
$
601
during
its
first
year
in
the
program.

2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
2(
a)
Need
and
Authority
for
the
Collection
As
stated
by
Congress
(
42
U.
S.
C.
#
13101­
13103.
1990)
and
EPA
(
The
Solid
Waste
Dilemma:
An
Agenda
for
Action.
1989
530­
SW­
89­
019.
pp.
16­
21),
there
are
significant
opportunities
for
businesses
to
reduce
or
prevent
pollution
at
the
source
through
cost­
effective
changes
in
production,
operation,
and
raw
material
use.
The
Agency
has
developed
a
hierarchy
asserting
that
waste
should
be
prevented
or
reduced
at
the
source
whenever
feasible;
waste
that
cannot
be
prevented
should
be
recycled
where
possible.
The
Pollution
Prevention
Act
of
1990
directs
the
EPA
Administrator
to
"
facilitate
the
adoption
of
source
reduction
techniques
by
businesses...,
foster
the
exchange
of
information
regarding
source
reduction
techniques...,
and
[
foster]
the
provision
of
technical
assistance
to
businesses
(
42
U.
S.
C.
#
13101­
13109.
1990)."
Furthermore,
the
Resource
Conservation
Challenge,
initiated
in
2002,
urges
Americans
to
increase
the
United
States'
recycling
rate
to
35
percent.
The
WasteWise
program
and
associated
information
collection
activities
will
assist
the
Agency
in
meeting
the
above
stated
goals
by
facilitating
the
prevention
and
recycling
of
wastes
by
participating
businesses.

More
specifically,
EPA
needs
to
collect
initial
information
in
the
Partner
Registration
Form
to
formally
establish
participation
in
the
WasteWise
program,
to
obtain
general
information
on
new
page
4
WasteWise
partners,
to
identify
the
facilities
committed
to
implementing
the
WasteWise
initiatives,
and
to
gain
insight
on
new
partners'
areas
of
interests/
priorities.

EPA
also
needs
to
collect
the
information
in
the
Annual
Assessment
Form
to
better
understand
and
assist
each
partner's
waste
reduction
efforts
and
progress
and
to
identify
effective
waste
reduction
strategies
to
share
with
others.
Furthermore,
as
mentioned
earlier,
by
compiling
new
partners'
baseline
waste
reduction
data,
WasteWise
will
be
able
to
more
accurately
determine
the
influence
that
WasteWise
has
on
its
partners'
waste
reduction
efforts.

For
the
WasteWise
Endorser
Program,
EPA
needs
to
collect
initial
information
in
the
Endorser
Registration
Form
to
establish
participation
in
the
Endorser
Program
and
to
obtain
general
contact
and
membership
information,
as
applicable.
EPA
also
needs
to
collect
the
information
on
recruitment
and
ongoing
activities
to
remain
apprized
of
endorser
activities
to
bring
new
partners
into
the
WasteWise
program.

2(
b)
Practical
Utility/
Users
of
the
Data
The
information
collected
by
the
WasteWise
program
is
not
designed
or
intended
to
support
regulatory
decision­
making
by
OSW
or
other
EPA
offices.
These
data
are
voluntarily
reported
by
individual
WasteWise
partners.
The
data
represent
partners'
estimates
of
progress
they
make
towards
waste
reduction
goals,
including
waste
prevention,
recycling
collection,
and
buying
or
manufacturing
recycledcontent
products
activities.
EPA
does
not
conduct
facility
audits
of
WasteWise
partners,
however,
a
quality
assurance/
quality
control
process
is
in
place
to
review
partner
reports
for
adherence
to
goals.
The
data
are
published
for
the
purpose
of
sharing
information
about
WasteWise
partners'
programs
and
to
encourage
other
organizations
to
explore
and
implement
waste
reduction
activities.

Specifically,
OSW
uses
the
information
collected
in
the
Partner
Registration
Form
to
update
WIES,
which
contains
information
on
WasteWise
participants,
initiate
contact
with
the
primary
person
in
charge
of
the
member's
WasteWise
initiatives,
and
prepare
a
list
of
WasteWise
partners.
The
information
in
WIES
is
used
to
track
organization
status,
prepare
reports
and
mailing
lists,
and
determine
the
focus
of
future
WasteWise
outreach
materials
(
based
on
partners'
identified
priorities).

OSW
uses
the
information
collected
in
the
Annual
Assessment
Forms
to
record
the
participant's
activities
and
progress
in
WIES;
identify,
develop,
and
disseminate
case
studies
and
other
materials
on
key
waste
reduction
practices
(
e.
g.,
to
be
published
in
the
WasteWise
Update
or
to
be
recommended
to
partners
seeking
new
waste
reduction
goals);
identify
areas
where
additional
technical
assistance
or
information
would
be
useful
for
individual
partners
or
more
generally
for
program
participants
(
e.
g.,
high
recycling
figures
for
corrugated
paperboard
might
indicate
an
opportunity
for
transport
packaging
reductions);
recognize
organizations
with
significant
waste
reduction
accomplishments
at
national
recognition
ceremonies;
organize
the
information
in
order
to
prepare
and
publish
a
summary
report
each
year;
evaluate
opportunities
for
improving
the
WasteWise
program,
and
measure
the
program's
progress
(
either
based
on
the
baseline
data
or
using
the
econometric
methodology).

OSW
uses
the
general
information
collected
in
the
Endorser
Registration
Form
to
update
WIES,
which
contains
information
on
WasteWise
endorsers;
initiate
contact
with
the
primary
person
in
charge
of
the
endorser's
WasteWise
initiatives;
and
prepare
a
list
of
WasteWise
endorsers.
The
information
in
WIES
is
used
to
track
organization
status
and
prepare
reports
and
mailing
lists.
OSW
uses
the
activity
page
5
information
collected
in
the
form
to
learn
about
promotional
activities
and
share
successful
strategies
with
other
endorsers
as
appropriate
and
offer
assistance
for
these
activities
as
necessary,
such
as
providing
materials
for
mailings
or
speakers
for
conferences.

3.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
3(
a)
Nonduplication
The
information
to
be
obtained
under
this
ICR
has
not
been
collected
by
EPA
or
any
other
federal
agency.
Other
nonfederal
organizations
sponsor
voluntary
programs
that
promote
recycling
collection
or
buying
recycled
products,
but
do
not
offer
a
comprehensive
waste
reduction
program
that
emphasizes
the
cost
saving
and
climate
benefits
of
waste
reduction.
OSW
is
continuing
to
work
with
these
non­
EPA
programs,
such
as
the
National
Recycling
Coalition's
(
NRC's)
Source
Reduction
Forum
and
the
Buy
Recycled
Business
Alliance
(
BRBA),
to
ensure
that
efforts
are
not
duplicative.
For
example,
WasteWise
previously
coordinated
with
BRBA
to
produce
a
national
satellite
forum
on
buying
recycled­
content
products.

3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
EPA
published
a
Federal
Register
notice
on
June
30,
2005
(
70
FR
37818)
seeking
public
comment
on
this
information
collection.
No
comments
were
received.

3(
c)
Consultations
In
evaluating
the
new
Registration
Form
and
Annual
Assessment
Form,
as
part
of
the
ICR
renewal
process,
WasteWise
staff
conducted
personal
interviews
with
program
partners
to
discuss
the
new
format
and
requested
information.
Interviews
were
conducted
with
the
following
seven
WasteWise
partners:

Albert
Fralinger
856
224­
1638
Public
Service
Enterprise
Group
Bradford
Hill
212
363­
3180
Evelyn
Hill
Inc.

John
O'Donoghue
585
588­
4741
Eastman
Kodak
Company
Tom
Watson
206
296­
4481
King
County,
WA
Don
Curran
501
329­
2901
Virco
Mfg.
Corporation
John
Bernardo
208
395­
4990
Albertsons,
Inc.

Edward
Newman
740
593­
0231
Ohio
University
Facilities
Management
Overall,
these
partners
("
participating
partners")
seemed
pleased
with
the
proposed
forms.
John
Bernardo,
from
Albertsons,
Inc.,
summed
up
the
reaction
of
many
participating
partners:
"
The
forms
are
so
much
more
succinct,
easier
to
fill
out,
and
all
in
all
an
improvement
to
the
registration
and
reporting
processes."
He
also
stated,
"
The
previous
forms
seemed
overwhelming,
and
actually
deterred
me
from
joining
the
program
(
even
while
being
marketed
by
WasteWise
and
by
Seydel
Companies)
for
over
a
year."
Some
other
comments
received
include:
page
6
°
"
The
new
forms
will
decrease
our
reporting
time
to
WasteWise
by
about
half."
°
"
The
new
forms
are
almost
too
easy
to
fill
out."
°
"
The
new
forms
provide
less
pressure
from
EPA
on
goals
in
specific
areas
and
provide
more
options
to
partners
to
tailor
their
individual
programs."

Based
on
the
feedback
we
received,
it
seems
that
the
participating
partners
believed
the
Registration
Form
will
have
a
positive
effect
on
the
program.
Many
participating
partners
appreciated
the
new
section
of
the
form
which
requests
partners
consider
some
of
their
top
waste
reduction
priorities,
making
them
think
about
activities
right
from
the
start.
The
participating
partners
thought
the
new
Annual
Assessment
Form,
which
combines
the
old
goals
form
and
the
old
annual
reporting
form,
was
also
an
effective
method
to
report
achievements
and
reduce
their
reporting
burden.
The
participating
partners
agreed
that
these
forms
are
a
nice
change
for
the
WasteWise
program.

WasteWise
continues
to
listen
to
its
partners'
feedback.
Many
years
ago,
partners
suggested
that
WasteWise
provide
an
electronic
reporting
option.
In
response
to
these
requests,
WasteWise
continues
to
offer
online
and
downloadable
forms,
and
improves
these
tools
when
necessary.
(
Although
the
electronic
options
reduce
paper
generation,
they
do
not
significantly
impact
respondent
burden
hours.)
Moreover,
as
part
of
this
ICR
process,
WasteWise
received
comments
on
the
Registration
Form
and
the
Annual
Assessment
Form,
which
were
taken
into
consideration
when
finalizing
the
forms.
Based
on
the
feedback
EPA
received,
the
Agency
recalculated
the
burden
hours
for
the
Registration
Form
and
the
Annual
Assessment
Form
mainly
because
the
original
two
forms
(
goals
and
reporting)
were
combined
and
the
program
is
now
asking
partners
for
different
information,
such
as
specific
waste
reduction
data.

3(
d)
Effects
of
Less
Frequent
Collection
The
Partner
Registration
Form
and
Endorser
Registration
Form
are
one­
time
information
submittals
for
organizations
that
wish
to
participate
in
the
WasteWise
program
as
endorsers
and/
or
partners.
Partners
submit
the
Annual
Assessment
Form
with
waste
reduction
baseline
data
and
goals
within
two
months
of
registering.
The
same
form
is
submitted
again
by
March
31
of
each
year,
this
time
with
the
partner's
annual
waste
reduction
data.
Requesting
this
report
on
a
less
frequent
basis
would
hinder
Agency
efforts
to
generate
relevant
and
timely
case
studies
and
success
stories
that
are
helpful
to
participants.
It
also
would
hinder
the
ability
of
the
Agency
to
review
the
activities
by
individual
organizations
and
the
program
as
a
whole
and
to
gain
the
information
necessary
to
publicly
recognize
significant
partner
waste
reduction
activities.

3(
e)
General
Guidelines
All
of
the
collection
activities
described
within
this
ICR
fall
within
OMB's
General
Guidelines.

3(
f)
Confidentiality
No
information
collected
by
EPA
under
the
WasteWise
program
comprises
confidential
business
information.

3(
g)
Sensitive
Questions
No
questions
of
a
sensitive
nature
are
asked
in
any
of
the
three
forms.

4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
page
7
4(
a)
Respondents
and
NAICS
Codes
The
WasteWise
program
was
initially
targeted
to
the
Fortune
500
manufacturing
companies
and
the
Fortune
500
service
companies.
During
the
period
covered
by
this
ICR,
however,
WasteWise
will
continue
to
focus
its
marketing
efforts
on
a
broader
audience,
including
medium
to
large
size
businesses,
universities,
and
federal/
state/
local/
tribal
governments.
While
WasteWise
actively
promotes
the
program
to
a
smaller
subset
of
these
groups,
the
program
is
open
to
all
companies,
trade
associations,
nonprofit
organizations,
schools,
colleges,
universities,
and
federal/
state/
local/
tribal
governments.

Due
to
the
broad
universe
of
eligible
WasteWise
partners,
a
relevant
list
of
NAICS
codes
would
include
virtually
every
business
area
contained
in
the
NAICS
code
manual.
Therefore,
it
is
not
practical
to
include
such
a
comprehensive
list
of
affected
organizations
in
this
supporting
statement.

The
WasteWise
Endorser
Program
initially
targeted
more
than
100
trade
associations
across
numerous
industry
sectors.
The
program
is,
however,
open
to
all
trade
associations,
membership
organizations,
and
federal/
state/
local/
tribal
organizations
in
this
supporting
statement.

4(
b)
Information
Requested
Once
a
prospective
partner
organization
reviews
the
WasteWise
materials
and
decides
to
join
the
program,
it
submits
a
Partner
Registration
Form
(
Attachment
B).
Within
six
months
of
registering,
new
partners
are
asked
to
complete
an
Annual
Assessment
Form
(
Attachment
C)
to
provide
WasteWise
with
baseline
waste
reduction
data
and
goals.
By
March
1
of
each
year,
partners
that
joined
the
program
by
August
1
of
the
preceding
year
report
on
the
progress
made
toward
achieving
their
goals
in
the
Annual
Assessment
Form.

Organizations
that
join
the
WasteWise
Endorser
Program
need
only
submit
the
Endorser
Registration
Form
(
Attachment
D)
at
the
time
they
join.

Partner
Registration
Form
Program
participants
complete
and
submit
to
EPA
a
standard,
one­
page
Partner
Registration
Form
that
provides
basic
organization
information.

(
i)
Data
items:

The
reporting
items
include:

$
How
the
member
heard
about
the
WasteWise
Program
(
choose
from
a
list
of
nine).

$
Organization
name,
parent
organization
name
(
if
applicable),
and
industry
sector.

$
Name,
title,
address,
phone
number,
fax
number,
and
email
address
of
the
partner's
primary
contact
person.

$
The
facilities
to
be
included
in
the
initial
waste
reduction
efforts
(
e.
g.,
corporate
page
8
headquarters
only,
regional
facilities,
all
plants,
etc.).

$
Approximate
number
of
employees
at
the
joining
facilities.

$
Waste
reduction
priorities
that
they
will
focus
on
as
part
of
their
membership
in
WasteWise.

$
Signature,
name,
and
title
of
senior
official
and
the
date
signed.

(
ii)
Respondent
activities:

Participants
conduct
the
following
activities
in
order
to
complete
and
submit
the
Partner
Registration
Form:

$
Review
the
WasteWise
brochure,
form,
and
other
necessary
materials.

$
Decide
which
facilities
will
join
the
WasteWise
Program.

$
Select
a
primary
contact
person
for
the
WasteWise
Program.

$
Provide
feedback
to
WasteWise
on
the
organization's
waste
reduction
priorities.

$
Complete
the
Partner
Registration
Form,
including
obtaining
the
signature
of
a
senior
official.

$
Send
the
completed
form
to
EPA
via
fax,
mail,
or
online.

Annual
Assessment
Form
Program
participants
complete
and
submit
to
EPA
a
standard,
two­
page
Annual
Assessment
Form
that
describes
the
participant's
waste
reduction
achievements
and
new
goals.
The
Annual
Assessment
Forms
contain
both
descriptive
information
and
quantified
results.
Additionally,
it
is
important
to
note
that
this
form
serves
two
purposes
by
allowing:

$
New
partners
to
provide
waste
reduction
baseline
data
and
goals
to
EPA
(
within
six
months
of
registering
to
be
part
of
the
program).

$
Existing
partners
to
report
on
the
previous
year's
waste
reduction
activities
by
March
1
of
each
year,
and
provide
new
goals
to
EPA.

(
i)
Data
items:

The
reporting
items
include:

$
Section
I:
Participant
Information
B
Organization
name.
page
9
B
Name,
phone
number,
and
email
address
of
the
partner's
primary
contact
person.

B
The
facilities
included
in
the
report
(
e.
g.,
corporate
headquarters
only,
regional
facilities,
all
plants,
etc.)
and
the
approximate
number
of
employees.

$
Section
II:
Current
Waste
Reduction
Activities
B
Total
amount
of
municipal
solid
waste
disposed
during
the
reporting
year.

­
B
Dates
that
the
report
covers
(
one
year's
worth
of
time).

For
all
of
the
previous
year's
waste
reduction
activities,
partners
provide
the
following
for
both
waste
prevention
and
recycling
activities:

B
Listing
of
the
product
or
material.

B
Description
of
the
waste
prevention/
recycling
activity.

B
The
volume
prevented/
recycled.

­
B
Goals
for
the
upcoming
year.

$
Section
III:
Cost
Savings/
Revenue
B
Total
waste
prevention
revenue.

B
Total
recycling
revenue.

B
Total
avoided
purchasing
costs
due
to
waste
prevention.

B
Total
avoided
disposal
costs
due
to
recycling
and
waste
prevention.

$
Section
IV:
Buying
or
Manufacturing
Recycled
Products
B
Listing
of
the
product
or
material.

B
Current
recycled
content
percent.

­­
Previous
recycled
content
percent.

­­
Current
units
purchased.

$
Section
V:
Comments
B
The
partner
may
attach/
share
additional
information
(
e.
g.
external
promotion,
employee
education,
program
comments,
etc.).
page
10
B
The
partner
may
attach/
share
additional
information
regarding
their
measurement
methodology
and
factors
that
may
affect
their
ability
to
reliably
determine
the
effect
of
the
program.

$
Signature
and
title
of
principal
contact
and
date.

WasteWise
assumes
that
this
information
is
kept
as
a
Common
Business
Practice
by
companies
implementing
internal
waste
reduction
programs.
Therefore,
burden
associated
with
recordkeeping
is
not
included
in
this
ICR.

(
ii)
Respondent
activities:

Participants
conduct
the
following
activities
in
order
to
complete
and
submit
the
Annual
Assessment
Form:

$
Collect
and
review
records
to
assess
progress
during
the
reporting
year.

$
Conduct
a
waste
assessment
or
account
for
annual
waste
reduction
efforts.

$
Review
records
to
assess
waste
reduction
progress.

$
Set
new
waste
reduction
goals.

$
Complete
the
Annual
Assessment
Form,
including
obtaining
the
signature
of
the
principal
contact.

$
Send
the
completed
form
to
EPA
via
fax,
mail,
or
online.

$
Respond
to
EPA
questions
to
clarify
data.

Endorser
Registration
Form
Endorsers
complete
and
submit
to
EPA
a
standard,
one­
page
Endorser
Registration
Form
that
provides
basic
association
information
and
describes
recruitment
and
promotional
activities.

(
i)
Data
items:

The
reporting
items
include:

$
Organization
name.

$
Name,
title,
address,
phone
number,
fax
number,
and
email
address
of
the
endorser's
principal
contact
person.

$
Approximate
number
of
business
members
in
the
organization.

$
List
of
primary
business
sectors
represented
by
the
organization
(
e.
g.,
NAICS
codes).

$
Description
of
proposed
recruitment
campaign
to
encourage
the
organization's
member
organizations
or
constituents
(
e.
g.,
local
businesses)
to
become
WasteWise
partners.
page
11
$
Description
of
proposed
ongoing
activities
to
promote
WasteWise
and/
or
provide
information
to
organization
members
on
waste
reduction
strategies
(
if
unknown,
the
organization
may
provide
this
information
to
EPA
at
a
later
date).

$
Signature,
name,
and
title
of
senior
official
and
the
date
signed.

(
ii)
Respondent
activities:

Endorsers
conduct
the
following
activities
in
order
to
complete
and
submit
the
Endorser
Registration
Form:

$
Review
the
WasteWise
Endorser
Program
information,
form,
and
overall
WasteWise
Program
information.

$
Determine
an
initial
recruitment
activities.

$
Consider
ongoing
promotional
activities.

$
Select
a
primary
contact
person
for
the
WasteWise
Endorser
Program.

$
Complete
the
Endorser
Registration
Form,
including
obtaining
the
signature
of
a
senior
official.

$
Send
the
completed
form
to
EPA
via
fax,
mail,
or
online.

5.
THE
INFORMATION
COLLECTED
C
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
5(
a)
Agency
Activities
Under
the
WasteWise
program,
EPA
engages
in
the
following
activities
related
to
the
three
forms:

Partner
Registration
Form
$
Distribute
Partner
Registration
Forms
to
potential
participants.

$
Answer
questions
posed
by
potential
participants
regarding
membership
in
the
program.

$
Receive
completed
forms,
record/
enter
information
into
a
database,
and
place
a
welcome
call
to
the
new
member.

$
Mail
new
partner
packets
to
participants.

Annual
Assessment
Form
$
Distribute
Annual
Assessment
Forms
to
new
partners
for
their
six
month
response
(
which
includes
waste
reduction
baseline
data
and
goals)
and
to
existing
partners
for
their
annual
reporting
to
WasteWise.

$
Develop
measurement
and
tracking
tools
to
assist
partners
in
the
reporting
process.
page
12
WasteWise
recently
updated
its
Online
Toolkit
by
updating
many
of
the
tools
found
in
EPA's
"
Business
Guide
for
Reducing
Solid
Waste"
and
making
them
available
online.
These
tools
will
help
organizations
calculate
their
waste
reduction
baseline,
track
their
waste
reduction
efforts,
and
much
more.

$
Maintain
a
tracking
system
and
develop/
revise
standard
data
reports.

$
Answer
questions
regarding
the
Annual
Assessment
Form.

$
Receive
and
review
the
form
for
consistency
and
completeness
and
place
any
follow­
up
calls
necessary.

B
Reported
Data
Quality.
The
assigned
WasteWise
account
representative
reviews
the
reporting
form
submitted
by
each
partner
for
which
he
or
she
is
responsible.
As
part
of
this
review,
representatives
determine
whether
the
reported
results
appear
consistent
with
the
volumes
reported
in
previous
years
by
the
partner
for
similar
activities.
If
a
representative
notices
a
report
where
the
numbers
are
exactly
the
same
or
appear
to
be
cumulative
rather
than
simply
for
the
current
reporting
year
period,
the
representative
calls
or
emails
the
partner
to
clarify
the
reported
results.
For
reported
amounts
above
1,000,000
pounds,
the
representative
contacts
the
partner
to
confirm
the
order
of
magnitude
and
to
prevent
any
errors
of
interpretation.
For
smaller
amounts,
representatives
look
to
see
if
the
results
appear
consistent
with
the
volumes
reported
in
previous
years
for
similar
activities.
In
addition,
reports
are
reviewed
to
ensure
that
only
acceptable
WasteWise
materials
and
activities
are
included
in
the
amounts
reported.
Only
after
this
thorough
review
is
completed
does
WasteWise
include
the
data
in
the
WasteWise
program
totals.

$
Record/
enter
information
into
WIES
and
conduct
quality
assurance/
quality
control
(
QA/
QC)
on
data
entry.

B
Data
Entry
Quality.
As
a
second
level
of
quality
control,
a
select
group
of
individuals
are
assigned
to
review
all
reports
after
they
have
been
entered
into
the
WasteWise
database.
These
individuals
work
with
the
account
representatives
to
correct
and
track
any
entries
where
a
large
number
does
not
appear
to
have
been
confirmed
or
where
numerical
data
have
been
entered
incorrectly
or
coded
improperly.

B
WAste
Reduction
Model
(
WARM)
Data
Entry
Quality.
As
a
third
check
of
the
numbers,
WasteWise
account
representatives
review
WARM
results
to
ensure
the
information
from
the
partner's
WasteWise
report
has
been
correctly
captured
in
this
spreadsheet.

$
Develop
and
make
publicly
available
an
annual
summary
of
program
activities
and
case
studies
of
significant
accomplishments.

Endorser
Registration
Form
$
Distribute
Endorser
Registration
Forms
to
potential
endorsers.
page
13
$
Answer
questions
posed
by
potential
endorsers
regarding
membership
in
the
program.

$
Receive
completed
forms,
record/
enter
information
into
a
database,
and
place
a
welcome
call
to
the
new
endorser.

$
Mail
new
endorser
packets
to
participants.

5(
b)
Collection
Methodology
and
Management
In
collecting
and
analyzing
the
information
associated
with
this
ICR,
EPA
uses
a
telephone
system,
personal
computers,
and
database
software.
EPA
ensures
the
reasonableness
and
completeness
of
collected
information
by
reviewing
each
submittal.
EPA
enters
the
information
obtained
from
the
three
forms
into
a
database.
The
Agency
uses
software
to
store
and
evaluate
data
obtained
from
Annual
Assessment
Forms.
The
data
are
used
to
identify
prominent
waste
reduction
strategies,
to
develop
and
publish
an
annual
summary
of
program
activities
and
case
studies
of
significant
accomplishments,
and
gear
the
program's
priorities
for
the
upcoming
year.

EPA
currently
offers
all
forms
in
hard
copy
and
electronically.
Electronic
forms
do
not
have
a
significant
impact
on
respondent
or
Agency
burden.

The
data
collected
under
this
ICR
are
voluntarily
reported
by
individual
WasteWise
partners.
The
data
represent
partners'
estimates
of
progress
they
made
towards
waste
reduction
goals
(
in
areas
such
as
waste
prevention,
recycling
collection,
and
buying
or
manufacturing
recycled­
content
products).
EPA
does
not
conduct
facility
audits
of
WasteWise
partners;
however,
a
QA/
QC
process
is
in
place
to
review
partner
reports
for
adherence
to
goals.
The
data
are
published
for
the
purpose
of
sharing
information
about
WasteWise
partners'
programs
and
to
encourage
other
organizations
to
explore
and
implement
waste
reduction
activities.
As
previously
mentioned,
WasteWise
developed
a
new
econometric
measurement
tool
to
accurately
determine
the
program's
accomplishments
for
existing
partners
and
will
use
the
baseline
data
to
assess
progress
for
new
partners.

5(
c)
Small
Entity
Flexibility
EPA
expects
that
some
of
the
participants
in
the
WasteWise
Program
will
be
small
entities.
EPA
has
designed
its
reporting
forms
to
minimize
respondent
burden
while
obtaining
sufficient
and
accurate
information.
The
WasteWise
Program
was
designed
to
be
highly
flexible.
Organizations
can
choose
the
number
of
facilities
to
include
in
the
program
and
choose
their
own
goals
based
on
individual
organization
resources.
In
addition,
the
burden
associated
with
the
WasteWise
Program
is
inherently
reduced
since
the
initial
agreement
to
participate
is
voluntary.
In
addition,
for
companies
with
fewer
than
50
employees
EPA
does
not
conduct
followup
if
Annual
Assessment
Forms
are
not
submitted.
These
partners
can
maintain
their
WasteWise
participation
as
long
as
they
indicate
that
they
are
actively
conducting
waste
reduction
efforts.

5(
d)
Collection
Schedule
Organizations
may
submit
Partner
Registration
Forms
to
join
the
WasteWise
Program
at
any
time.
Within
six
months
after
a
participant
joins
the
program,
it
should
submit
an
Annual
Assessment
Form.
All
existing
partners'
Annual
Assessment
Forms
are
due
to
EPA
by
March
31
of
every
year
that
the
partner
participates
in
the
program.
page
14
Trade
associations
and
other
membership­
based
organizations
may
submit
Endorser
Registration
Forms
to
join
the
WasteWise
Endorser
Program
at
any
time.

6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
6(
a)
Estimating
Respondent
Burden
Exhibit
1
(
see
page
14)
presents
the
burden
hours
and
costs
per
respondent
as
well
as
for
all
respondents
during
each
of
the
three
years
covered
under
this
ICR.

The
Partner
Registration
Form
contains
basic
questions,
thus
the
burden
is
expected
to
be
minimal.
The
overall
burden,
as
shown
in
the
table,
is
estimated
to
be
one
hour
per
participant.
This
burden
level
is
an
estimate
based
on
nine
years
of
WasteWise
program
experience.
The
burden
estimate
for
the
Partner
Registration
Form
is
for
reporting
only.

Completing
the
Annual
Assessment
Form
entails
assessment,
reporting,
and
recordkeeping
activities.
The
overall
annual
labor
burden
for
partners
is
expected
to
average
40
hours
per
participant.
Burden
hours
for
the
Annual
Assessment
Form
are
for
conducting
a
waste
assessment
to
analyze
waste
reduction
opportunities,
setting
up
a
tracking
system,
and
mainly
for
reporting
activities.

New
partners
joining
WasteWise
are
estimated
to
spend
41
hours
(
one
hour
on
the
Partner
Registration
Form
and
40
hours
on
the
Annual
Assessment
Form)
on
the
information
collection
activities
in
the
first
year
of
membership,
and
40
hours
(
on
the
Annual
Assessment
Form)
for
subsequent
years
in
the
program.

The
Endorser
Registration
Form
asks
for
basic
information
and
requests
brief/
general
descriptions
of
promotional
activities,
thus
the
burden
is
expected
to
be
minimal.
The
overall
burden,
as
shown
in
Exhibit
1,
is
estimated
to
be
10
hours
per
participant.
All
burden
hours
for
the
Endorser
Registration
Form
are
for
reporting
only.

The
average
WasteWise
endorser
will
spend
10
hours
on
the
information
collection
activities
in
its
first
year
as
an
endorser
and
will
incur
no
further
information
collection
burden
in
subsequent
years.

6(
b)
Estimating
Respondent
Costs
In
previous
ICRs,
EPA
had
estimated
an
average
hourly
labor
rate
(
hourly
rate
plus
overhead)
of
$
75
for
managerial
staff,
$
49
for
technical
staff,
and
$
29
for
clerical
staff.
For
this
supporting
statement,
EPA
updated
the
rates
to
reflect
the
civilian
wages
listed
in
the
Bureau
of
Labor
Statistics'
"
Employer
Costs
for
Employee
Compensation"
report
dated
June
2005.
(
This
report
is
currently
located
on
the
Bureau
of
Labor
Statistics'
Web
site
at
<
http://
www.
bls.
gov/
schedule/
archives/
ecec_
nr.
htm#
2005>).
The
rates
from
this
table
were
$
47.20
for
managerial
staff,
$
30.54
for
technical
staff,
and
$
18.88
for
clerical
staff.
EPA
added
an
additional
110
percent
to
this
rate
to
reflect
burden
overhead.
The
resulting
rates
which
EPA
used
to
calculate
the
burden
costs
are
$
93.10
for
managerial
staff,
$
64.13
for
technical
staff,
and
$
39.65
for
clerical
staff.
No
capital
or
operations
and
management
costs
are
incurred
by
respondents
under
this
ICR.
page
15
Respondent
Labor
Costs
(
hourly
rate
plus
110
percent
overhead)

Labor
Category
Rate
on
Table
Rate
plus
110
percent
Management
$
42.40
$
89.04
Service­
Providing
$
25.34
$
53.21
Office
$
19.69
$
41.34
Exhibit
1,
on
the
following
page,
presents
the
estimated
burden
for
WasteWise
partners
based
on
each
form.
This
information
is
based
on
the
following
data:
Existing
WasteWise
Partners
=
1,400
New
Partners
Per
Year
=
100
Existing
WasteWise
Endorsers
=
250
New
Endorsers
Per
Year
=
25
page
16
Total
Hours
Management
Technician
Administrative
Review
form
0.75
0.25
0.5
0
$
49
75
$
4,887
75
$
4,887
75
$
4,887
Complete/
transmit
form
0.25
0
0
0.25
$
10
25
$
1,034
25
$
1,034
25
$
1,034
SUBTOTAL
1
0.25
0.5
0.25
$
59
100
$
5,920
100
$
5,920
100
$
5,920
Collect
records
and
conduct
a
waste
assessment
OR
account
for
annual
efforts
20.5
2
11.5
7
$
1,079
26,650
$
1,403,188
28,700
$
1,511,125
30,750
$
1,619,063
Review
records
to
assess
progress
6
2
4
0
$
391
7,800
$
508,196
8,400
$
547,288
9,000
$
586,380
Set
goals
10
1
8
1
$
556
13,000
$
722,878
14,000
$
778,484
15,000
$
834,090
Complete/
transmit
form
2.5
0
2
0.5
$
127
3,250
$
165,217
3,500
$
177,926
3,750
$
190,635
Respond
to
EPA
Questions
1
0
1
0
$
53
1,400
$
69,173
1,500
$
74,494
1,600
$
79,815
SUBTOTAL
40
5
26.5
8.5
$
2,207
52,100
$
2,868,652
56,100
$
3,089,317
60,100
$
3,309,983
52,200
$
2,874,572
56,200
$
3,095,237
60,200
$
3,315,903
New
partner
­
submitting
registration
form
and
submitting
6­
month
Annual
Assessment
Form
(
baseline
data)
41
5.25
27
8.75
$
2,266
Partner
­
submitting
Annual
Assessment
Form
40
5
26.5
8.5
$
2,207
Review
form
0.75
0
0.75
0
$
40
18.75
$
998
18.75
$
998
18.75
$
998
Determine
activities
9
2
7
0
$
551
225
$
13,764
225
$
13,764
225
$
13,764
Complete/
transmit
form
0.25
0
0
0.25
$
10
6.25
$
258
6.25
$
258
6.25
$
258
TOTAL
COST
TO
ALL
ENDORSER
RESPONDENTS
10
2
7.75
0.25
$
601
250
$
15,020
250
$
15,020
250
$
15,020
Cost
per
Activity
Total
Cost
per
Year
Total
Hours
per
Year
Total
Hours
per
Year
Total
Cost
per
Year
Total
Hours
per
Year
Total
Cost
per
Year
ENDORSER
REGISTRATION
FORM
Burden
Hours
&
Individual
Costs
for
All
Years
Year
1
Costs
Year
2
Costs
Year
3
Costs
PARTNER
REGISTRATION
FORM
ANNUAL
ASSESSMENT
FORM
COST
TO
PARTNERS
Hours
per
Respondent
per
Activity
Total
cost
to
all
partners
Exhibit
1.
An
page
17
6(
c)
Estimating
Exhibit
2
presents
the
collection
activities
under
are
also
included.
EPA
based
program
and
interacting
with
pa
The
Agency
expects
most
activities
u
percent)
and
technical
staff
(
75
percent).

percent
of
the
work
(
with
technical
staff
at
Since
one
year
has
past
since
the
last
ICR
submis
current
GS
rates
$
30.90
for
managerial
staff
(
GS1
for
clerical
staff
(
GS7­
1).
EPA
multiplied
wages
by
1.6
The
resulting
rates
which
EPA
used
to
recalculate
the
burd
for
technical
staff,
and
$
23.44
for
clerical
staff.

EPA
still
expects
to
have
contractor
support
for
various
as
collection
under
this
ICR
and
has
included
contractor
costs
in
estim
estimated
based
on
the
rates
for
the
current
contractor
ERG,
are
$
80.00
fo
for
technical
staff
so
the
average
hourly
rates
are
proportional
to
the
percenta
given
task.

Agency
Labor
Costs*

EPA/
Contractor
Share
Management
Technical
Administrativ
e
Management
(%
performed)
Technical
(%
performed)
Administrativ
e
(%
performed)
Average
Hourly
Rate**
100%
EPA
$
49.44
$
41.57
$
23.44
25%
74%

1%

$
38.15
0%
Contractor
$
0.00
$
0.00
$
0.00
0%
0%
1%

$
0.00
TOTAL
$
49.44
$
41.57
$
23.44
­
­
­
$
38.15
25%
EPA
$
12.36
$
10.39
N/
A
25%
75%

0%

$
11.38
75%
Contractor
$
60.00
$
30.00
N/
A
25%
75%

0%

$
37.50
TOTAL
$
71.74
$
39.87
N/
A
­
­
­
$
48.88
0%
EPA
$
0.00
$
0.00
N/
A
25%
75%

0%

$
0.00
100%
Contractor
$
80.00
$
40.00
N/
A
25%
75%

0%

$
50.00
TOTAL
$
80.00
$
40.00
N/
A
­
­
­
$
50.00
*
EPA
=
hourly
rate
plus
60
percent
overhead
Contractor
=
hourly
rate
includes
overhead
**
Based
on
shared
activities/
costs
by
EPA
and
contractor
page
18
Hours
Costs
Hours
Costs
Hours
Cost
Distribute
Forms
$
48.88
250
$
12,220
$
1,000
$
13,220
250
$
12,220
$
1,000
$
13,220
250
$
12,220
$
1,000
$
13,220
Answer
Questions
$
50.00
500
$
25,000
$
2,000
$
27,000
500
$
25,000
$
2,000
$
27,000
500
$
25,000
$
2,000
$
27,000
Record/
Enter
Forms
$
50.00
75
$
3,750
$
300
$
4,050
75
$
3,750
$
300
$
4,050
75
$
3,750
$
300
$
4,050
Mail
Out
Member
Packets
$
50.00
113
$
5,650
$
450
$
6,100
113
$
5,650
$
450
$
6,100
113
$
5,650
$
450
$
6,100
SUBTOTAL
938
$
46,620
$
3,750
$
50,370
938
$
46,620
$
3,750
$
50,370
938
$
46,620
$
3,750
$
50,370
Distribute
Forms
$
48.88
240
$
11,731
$
960
$
12,691
278
$
13,589
$
1,110
$
14,699
315
$
15,397
$
1,260
$
16,657
Develop/
Maintain
Tracking
System
$
50.00
250
$
12,500
0
$
12,500
250
$
12,500
0
$
12,500
250
$
12,500
0
$
12,500
Answer
Questions/
Review/
Followup
$
48.88
2,000
$
97,760
$
7,680
$
105,440
2,100
$
102,648
$
8,880
$
111,528
2,200
$
107,536
$
10,080
$
117,616
Record/
Code/
Enter
Forms
$
50.00
1,500
$
75,000
0
$
75,000
1,600
$
80,000
0
$
80,000
1,700
$
85,000
0
$
85,000
QA/
QC
Data
$
50.00
1,500
$
75,000
0
$
75,000
1,600
$
80,000
0
$
80,000
1,700
$
85,000
0
$
85,000
Develop/
Publish
Annual
Summary
$
48.88
800
$
39,104
$
1,200
$
40,304
800
$
39,104
$
1,200
$
40,304
800
$
39,104
$
1,200
$
40,304
SUBTOTAL
6,290
$
311,095
$
9,840
$
320,935
6,628
$
327,841
$
11,190
$
339,031
6,965
$
344,537
$
12,540
$
357,077
Distribute
Forms
$
48.88
5
$
244
$
20
$
275
5
$
255
$
20
$
275
5
$
255
$
20
$
275
Answer
Questions
$
48.88
10
$
489
$
40
$
550
10
$
510
$
40
$
550
10
$
510
$
40
$
550
Record/
Enter
Forms
$
50.00
10
$
500
$
20
$
520
10
$
500
$
20
$
520
10
$
500
$
20
$
520
Mail
Endorser
Packet
$
50.00
5
$
250
$
180
$
430
5
$
250
$
180
$
430
5
$
250
$
180
$
430
SUBTOTAL
30
$
1,483
$
260
$
1,775
30
$
1,515
$
260
$
1,775
30
$
1,515
$
260
$
1,775
Total
Cost
7,258
$
359,198
$
13,850
$
373,080
7,596
$
375,976
$
15,200
$
391,176
7,933
$
392,672
$
16,550
$
409,222
COST
TO
EPA
Labor
Labor
Labor
Other
Direct
Costs
Total
Costs
Other
Direct
Costs
Total
Costs
Other
Direct
Costs
Total
Costs
ANNUAL
ASSESSMENT
FORM
PARTNER
REGISTRATION
FORM
ENDORSER
REGISTRATION
FORM
YEAR
1
YEAR
2
YEAR
3
Average
Hourly
Rate
Exhibit
2.
page
19
FORM
NUMBER
OF
RESPONDENTS
BURDEN
HOURS
COST
(
in
dollars)
YEAR
1
Partner
Registration
100
100
$
5,920
Annual
Assessment
or
Baseline
Data
Submission
1400
52,350
$
2,874,572
Endorser
Registration
25
250
$
15,020
Year
1
Bottom
Line
*
1,425
52,700
$
2,895,512
YEAR
2
Partner
Registration
100
100
$
5,920
Annual
Assessment
or
Baseline
Data
Submission
1,500
56,350
$
3,095,237
Endorser
Registration
25
250
$
15,020
Year
2
Bottom
Line
*
1,525
56,700
$
3,116,177
YEAR
3
Partner
Registration
100
100
$
5,920
Annual
Assessment
or
Baseline
Data
Submission
1,600
60,350
$
3,315,903
Endorser
Registration
25
250
$
15,020
Year
3
Bottom
Line
*
1,625
60,700
$
3,336,843
3­
YEAR
TOTAL
4,575
170,100
$
9,348,532
6(

d)

Estimating
the
Resp
The
WasteWise
Prog
partners
to
jo
Registration
partners
estim
need
to
subm
information
(

currently
has
therefore
onl
submit
them.

6(

e)

Bottom
Line
Burden
Hours
The
bottom
line
burd
estimated
nu
There
are
var
respondents
i
Table
1.

Bottom
Line
Burden
and
Costs
to
Respondent
page
20
YEAR
BURDEN
HOURS
COST
Year
1
7,258
$
373,080
Year
2
7,596
$
391,176
Year
3
7,933
$
409,222
Year
3
Bottom
Line
22,787
$
1,173,478
*
Bottom
line
dat
and
endorser
registra
The
bottom
line
burden
and
costs
to
EPA
also
vary
each
year,

according
to
the
number
of
respondents.

Table
2
indicated
the
Agency's
bot
Table
2.

Bottom
Line
Burden
and
Costs
to
6(

f)

Reasons
for
Change
Since
the
last
clearan
affect
inform
Adjustments
$

Changes
in
Wage
Rates.

EP
updated
rates
on
the
Bureau
o
<

http://

www.

bls.

gov/

schedul
burden
costs
to
the
Agency
to
did
not
impact
burden
hours.

$

Variation
in
Number
of
Par
partners
will
join
during
each
WasteWise
Endorser
Program
6(

g)

Burden
Statement
The
reporting
burden
Partner
Reg
to
review
Wa
The
reporting
burden
Annual
Asse
to
conduct
a
complete
and
The
reporting
burden
Endorser
Re
time
to
review
page
21
promotional
Burden
means
the
tot
maintain,

reta
to
review
ins
collecting,

va
and
providin
and
requirem
complete
and
agency
may
n
unless
it
disp
regulations
a
To
comment
on
the
A
estimates,

an
collection
tec
0010,

which
EPA
West,

R
Reading
Roo
The
telephon
Docket
is
(

20
(

EDOCKET)

the
index
list
that
are
avail
identified
abo
of
Manageme
EPA.

Please
in
any
corres
1
In
some
partners.

We
page
22
Attachment
A
METHODOLOGY
FOR
WASTEWISE
MULTI­
STAGE
STATISTICAL
ANALYSIS
The
method
used
to
estimate
the
WasteWise
impact
accounts
for
two
data
facts:
(
1)
not
all
WasteWise
partners
report
waste
prevention
and
recycling
data
and
(
2)
we
have
no
information
on
waste
prevention
and
recycling
among
nonpartners.
To
account
for
these
data
problems,
EPA
developed
a
method
that
relies
on
statistical
modeling
to
account
for
the
missing
data.
One
important
fact,
however,
is
that
although
we
do
not
have
waste
prevention
and
recycling
data
for
non­
reporting
partners
and
non­
partners,
we
do
have
access
to
other
information
on
these
companies
(
e.
g.,
financial
information,
size).
Use
of
this
other
information
helps
us
to
control
for
the
fact
that
we
are
missing
outcome
(
i.
e.,
waste
prevention
and
recycling)
data.
In
statistical
terms,
we
have
censored
data.
Thus,
although
we
are
missing
outcome
data
for
some
companies,
we
know
which
companies
are
missing
data
and
we
have
other
information
on
these
companies.

The
method
can
best
be
described
as
a
multi­
stage
statistical
analysis
that
uses
statistical
modeling
to
develop
control
variables
to
overcome
the
lack
of
outcome
data.
In
the
first
part
of
the
analysis,
we
look
at
what
influences
firms'
decisions
to
join
WasteWise.
From
this
analysis
we
create
a
variable
that
reflects
the
probability
that
a
firm
is
a
WasteWise
partner.
1
In
the
second
part
of
the
analysis,
we
measure
how
a
number
of
factors,
including
the
probability
of
being
a
WasteWise
partner,
affect
waste
prevention
and
recycling.
The
relationship
between
the
probability
of
being
a
WasteWise
partner
and
the
outcome
variables
(
waste
prevention
and
recycling)
will
determine
the
program
effect
of
WasteWise.

Using
the
probability
of
being
a
WasteWise
partner
adjusts
for
the
lack
of
outcome
data
for
nonpartners.
To
understand
this,
consider
the
situation
where
outcome
data
are
available
for
both
partners
and
nonpartners.
We
will
refer
to
this
as
the
full
data
scenario.
In
this
situation,
we
can
construct
a
binary
variable
equal
to
one
if
the
firm
was
a
partner
and
zero
if
not.
The
statistical
analysis
would
then
compare
outcomes
among
partners
(
binary
variable
equal
to
one)
to
nonpartners
(
binary
variable
equal
to
zero)
while
controlling
for
other
relevant
factors
(
size,
financial
status).
The
difference
between
outcomes
for
partners
and
nonpartners
after
controlling
for
other
relevant
factors
is
the
program
effect
of
WasteWise.
This
type
of
analysis
is
not
possible
because
we
do
not
have
outcome
data
for
nonpartners.

To
develop
an
estimate
of
the
program
effect
in
the
absence
of
outcome
data
for
nonpartners,
we
have
developed
a
statistical
approach
that
combines
some
well­
accepted
methods.
In
terms
of
the
discussion
above,
we
transform
the
binary
variable
into
one
that
is
continuous
between
zero
and
one
(
i.
e.,
the
probability
of
being
a
partner).
In
the
full
data
scenario,
outcome
data
are
available
for
both
partners
and
nonpartners.
In
our
situation,
however,
outcome
data
are
only
available
for
cases
where
the
binary
variable
equals
one,
making
direct
comparison
impossible
because
there
is
no
variation
in
the
program
participation
measure.
To
get
around
this,
we
use
the
probability
of
being
a
partner
to
measure
the
degree
to
which
a
firm
is
part
of
the
program.
The
probability
of
being
a
WasteWise
partner
will
exhibit
variation
among
partners.
Firms
that
have
a
higher
probability
of
being
a
partner
should
also
perform
more
waste
prevention
and
recycling.
A
detailed
technical
justification
of
this
method
can
be
found
in
the
full
project
report
(
currently
under
peer
review).

The
second
part
of
the
analysis
also
adjusts
for
two
other
problems:
(
1)
some
partners
will
have
"
zero"
for
the
outcome
variable,
but
in
actuality,
probably
are
conducting
waste
reduction
initiatives
but
do
not
report
and
(
2)
there
will
be
some
firm­
specific
effects.
The
occurrence
of
"
zero"
values
for
waste
prevention
and
recycling
amounts
reflects
censoring
of
the
outcome
variable.
That
is,
we
expect
that
actual
waste
prevention
and
recycling
amounts
are
positive
for
those
companies,
but
since
the
companies
did
not
2
By
"
firm
specific
effects,"
we
mean
factors
that
we
cannot
measure
that
might
affect
the
data.
Examples
of
such
factors
include
corporate
culture
and
how
firms
measure
waste
prevention.

3
For
more
information
on
EPA's
WARM
model,
see
<
http://
yosemite.
epa.
gov/
oar/
globalwarming.
nsf/
content/
ActionsWasteWARM.
html>

page
23
report
a
value,
we
record
their
value
as
"
zero."
This
type
of
problem
is
not
uncommon
in
statistical
research,
and
a
variety
of
methods
have
been
developed
to
account
for
the
missing
data
in
a
regression
model
framework.
We
use
a
"
Tobit"
model
specification
to
handle
this
issue,
which
is
discussed
in
more
detail
in
the
full
report.

The
presence
of
"
firm­
specific
effects2"
reflects
the
nature
of
the
data.
Specifically,
we
have
a
number
of
partners
measured
over
time.
This
scenario
is
commonly
referred
to
as
panel
or
longitudinal
data.
In
such
a
framework,
unmeasured
differences
(
i.
e.,
the
firm­
specific
effects)
between
firms
can
lead
to
biased
estimates
for
the
variables
included
in
the
analysis.
A
number
of
methods
have
been
developed
to
account
for
the
presence
of
these
firm­
specific
effects.
We
use
the
random
effects
procedure
to
account
for
these
firm­
specific
effects,
which
is
discussed
in
more
detail
in
the
full
report.

Our
method
also
allows
us
to
estimate
a
waste
prevention
and
recycling
amount
for
non­
reporting
partners.
Thus,
once
the
analysis
has
defined
the
relationship
between
outcomes
and
the
control
factors,
we
can
use
the
estimated
statistical
model
to
fill
in
the
missing
values
for
non­
reporting
partners.
We
discuss
this
in
more
detail
in
the
full
report.

Finally,
to
meet
EPA's
goal
of
identifying
the
impact
of
WasteWise
on
our
global
climate,
the
method
must
also
provide
material­
specific
estimates
of
the
amount
of
waste
prevention
and
recycling
that
are
attributable
to
the
WasteWise
program.
While
the
statistical
analysis
provides
a
program
effect
for
categories
of
materials,
it
does
not
provide
a
material­
specific
estimate
needed
for
use
in
EPA's
WARM
model3.
There
are
two
separate
questions
that
need
resolution
in
this
area:
(
1)
What
will
be
the
program
effect
for
specific
materials
if
we
only
have
category­
level
estimates
of
the
program
effect?
and
(
2)
How
do
we
estimate
the
amount
of
waste
prevention
and
recycling
of
specific
materials
for
non­
reporting
partners
if
we
only
have
category­
level
estimates
of
these
amounts
for
non­
reporting
partners?
The
first
can
be
resolved
with
a
reasonable
assumption:
that
is,
we
assume
that
the
category­
level
estimates
of
the
program
effect
can
be
applied
to
the
materials
within
each
category.

The
second
issue
requires
some
elaboration
before
describing
a
solution.
The
statistical
models
that
we
estimate
provide
a
category­
level
estimate
of
waste
prevention
and
recycling
for
non­
reporting
partners.
For
example,
the
statistical
model
for
plastics
waste
prevention
will
provide
an
estimate
of
the
amount
of
plastics
waste
prevention
achieved
by
non­
reporting
partners.
The
statistical
model
will
not,
however,
provide
material­
specific
estimates
of
waste
prevention
and
recycling.
This
is
not
an
issue
for
reporting
partners
since
they
have
reported
material­
specific
amounts.
To
determine
the
material­
specific
amounts
for
non­
reporting
partners,
we
use
the
distribution
of
materials
in
each
category
from
the
reported
partners,
stratified
by
industry
sector.
We
describe
this
approach
in
more
detail
in
the
full
report.
