SUPPORTING STATEMENT FOR 

INFORMATION COLLECTION REQUEST NUMBER 2285.01

“INFORMATION COLLECTIONS UNDER THE SCHOOLS CHEMICAL CLEANOUT CAMPAIGN
(SC3)”

September 25, 2008

Office of Solid Waste

United States Environmental Protection Agency

Washington, D.C. 20460

TABLE OF CONTENTS

  TOC \o "1-3" \h \z    HYPERLINK \l "_Toc207264721"  PART A OF
SUPPORTING STATEMENT	A-  PAGEREF _Toc207264721 \h  1  

  HYPERLINK \l "_Toc207264722"  1.	IDENTIFICATION OF THE INFORMATION
COLLECTION	A-  PAGEREF _Toc207264722 \h  1  

  HYPERLINK \l "_Toc207264723"  1(a)	Title and Number of the Information
Collection	A-  PAGEREF _Toc207264723 \h  1  

  HYPERLINK \l "_Toc207264724"  1(b)	Short Characterization	A-  PAGEREF
_Toc207264724 \h  1  

  HYPERLINK \l "_Toc207264725"  2.	NEED FOR AND USE OF THE COLLECTION	A-
 PAGEREF _Toc207264725 \h  2  

  HYPERLINK \l "_Toc207264726"  2(a)	Need and Authority for the
Collection	A-  PAGEREF _Toc207264726 \h  2  

  HYPERLINK \l "_Toc207264727"  2(b)	Practical Utility and Users of the
Data	A-  PAGEREF _Toc207264727 \h  6  

  HYPERLINK \l "_Toc207264728"  3.	NONDUPLICATION, CONSULTATIONS, AND
OTHER COLLECTION CRITERIA	A-  PAGEREF _Toc207264728 \h  8  

  HYPERLINK \l "_Toc207264729"  3(a)	Nonduplication	A-  PAGEREF
_Toc207264729 \h  8  

  HYPERLINK \l "_Toc207264730"  3(b)	Public Notice	A-  PAGEREF
_Toc207264730 \h  8  

  HYPERLINK \l "_Toc207264731"  3(c)	Consultations	A-  PAGEREF
_Toc207264731 \h  8  

  HYPERLINK \l "_Toc207264732"  3(d)	Effects of Less Frequent Collection
A-  PAGEREF _Toc207264732 \h  9  

  HYPERLINK \l "_Toc207264733"  3(e)	General Guidelines	A-  PAGEREF
_Toc207264733 \h  10  

  HYPERLINK \l "_Toc207264734"  3(f)	Confidentiality	A-  PAGEREF
_Toc207264734 \h  10  

  HYPERLINK \l "_Toc207264735"  3(g)	Sensitive Questions	A-  PAGEREF
_Toc207264735 \h  10  

  HYPERLINK \l "_Toc207264736"  4.	THE RESPONDENTS AND THE INFORMATION
REQUESTED	A-  PAGEREF _Toc207264736 \h  10  

  HYPERLINK \l "_Toc207264737"  4(a)	Respondents and NAICS Codes	A- 
PAGEREF _Toc207264737 \h  10  

  HYPERLINK \l "_Toc207264738"  4(b)	Information Requested	A-  PAGEREF
_Toc207264738 \h  11  

  HYPERLINK \l "_Toc207264739"  5.	THE INFORMATION COLLECTED:  AGENCY
ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT	A- 
PAGEREF _Toc207264739 \h  14  

  HYPERLINK \l "_Toc207264740"  5(a)	Agency Activities	A-  PAGEREF
_Toc207264740 \h  14  

  HYPERLINK \l "_Toc207264741"  5(b)	Collection Methodology and
Management	A-  PAGEREF _Toc207264741 \h  15  

  HYPERLINK \l "_Toc207264742"  5(c)	Small Entity Flexibility	A- 
PAGEREF _Toc207264742 \h  15  

  HYPERLINK \l "_Toc207264743"  5(d)	Collection Schedule	A-  PAGEREF
_Toc207264743 \h  16  

  HYPERLINK \l "_Toc207264744"  6.	ESTIMATING THE HOUR AND COST BURDEN
OF THE COLLECTION	A-  PAGEREF _Toc207264744 \h  16  

  HYPERLINK \l "_Toc207264745"  6(a)	Estimating Respondent Burden Hours
A-  PAGEREF _Toc207264745 \h  16  

  HYPERLINK \l "_Toc207264746"  6(b)	Estimating Respondent Costs	A- 
PAGEREF _Toc207264746 \h  16  

  HYPERLINK \l "_Toc207264747"  6(c)	Estimating Agency Hour and Cost
Burden	A-  PAGEREF _Toc207264747 \h  17  

  HYPERLINK \l "_Toc207264748"  6(d)	Estimating the Annual Respondent
Universe and Total Hour and Cost Burden	A-  PAGEREF _Toc207264748 \h  17
 

  HYPERLINK \l "_Toc207264749"  6(e)	Bottom-Line Hour and Cost Burden	A-
 PAGEREF _Toc207264749 \h  19  

  HYPERLINK \l "_Toc207264750"  6(f)	Reasons for Change In Burden	A- 
PAGEREF _Toc207264750 \h  19  

  HYPERLINK \l "_Toc207264751"  6(g)	Public Burden Statement	A-  PAGEREF
_Toc207264751 \h  20  

  HYPERLINK \l "_Toc207264752"  PART B OF SUPPORTING STATEMENT	B- 
PAGEREF _Toc207264752 \h  1  

  HYPERLINK \l "_Toc207264753"  1. 	Survey Objectives, Key Variables,
And Other Preliminaries	B-  PAGEREF _Toc207264753 \h  1  

  HYPERLINK \l "_Toc207264754"  1(a)  	Survey Objectives	B-  PAGEREF
_Toc207264754 \h  1  

  HYPERLINK \l "_Toc207264755"  1(b)  	Key Variables	B-  PAGEREF
_Toc207264755 \h  1  

  HYPERLINK \l "_Toc207264756"  1(c)  	Statistical Approach	B-  PAGEREF
_Toc207264756 \h  2  

  HYPERLINK \l "_Toc207264757"  1(d)  	Feasibility	B-  PAGEREF
_Toc207264757 \h  2  

  HYPERLINK \l "_Toc207264758"  2. 	Survey Design	B-  PAGEREF
_Toc207264758 \h  2  

  HYPERLINK \l "_Toc207264759"  2(a) 	Target Population and Coverage	B- 
PAGEREF _Toc207264759 \h  2  

  HYPERLINK \l "_Toc207264760"  2(b)	Sample Design	B-  PAGEREF
_Toc207264760 \h  2  

  HYPERLINK \l "_Toc207264761"  2(c)	Data Quality	B-  PAGEREF
_Toc207264761 \h  2  

  HYPERLINK \l "_Toc207264762"  2(d)	Questionnaire Design	B-  PAGEREF
_Toc207264762 \h  4  

  HYPERLINK \l "_Toc207264763"  3. 	Pretests And Pilot Tests	B-  PAGEREF
_Toc207264763 \h  5  

  HYPERLINK \l "_Toc207264764"  4. 	Collection Methods And Follow-up	B- 
PAGEREF _Toc207264764 \h  5  

  HYPERLINK \l "_Toc207264765"  4(a)  	Collection Methods	B-  PAGEREF
_Toc207264765 \h  5  

  HYPERLINK \l "_Toc207264766"  4(b)	 Survey Response And Follow-up	B- 
PAGEREF _Toc207264766 \h  6  

  HYPERLINK \l "_Toc207264767"  5. 	Analyzing And Reporting Survey
Results	B-  PAGEREF _Toc207264767 \h  6  

  HYPERLINK \l "_Toc207264768"  5(a)	Data Preparation	B-  PAGEREF
_Toc207264768 \h  6  

  HYPERLINK \l "_Toc207264769"  5(b)	Data Analysis and Reporting	B- 
PAGEREF _Toc207264769 \h  6  

 

PART A OF SUPPORTING STATEMENT

1.	IDENTIFICATION OF THE INFORMATION COLLECTION

1(a)	Title and Number of the Information Collection

This Information Collection Request (ICR) is entitled “Information
Collections under the Schools Chemical Cleanout Campaign (SC3),” EPA
ICR Number 2285.01.

1(b)	Short Characterization

The U.S. Environmental Protection Agency (EPA) launched the National
Schools Chemical Cleanout Campaign (SC3) Program in March of 2007.  The
National SC3 Program uses a variety of innovative approaches to achieve
three goals: (1) removal of outdated and dangerous chemicals from K-12
schools; (2) prevention of future accumulations of chemicals and
reduction of accidents by establishing prevention activities such as
good purchasing and management practices; and, (3) raising national
awareness of the problem.  

EPA intends to collect some information from Program Partners to further
develop, implement, and improve the SC3 Program.  Specifically, EPA
would like to conduct an annual survey of organizations that partner
with EPA under SC3, to learn about their experiences and needs under the
Program.  This will help EPA to evaluate and improve the Program and
share information about the Program with others.  In addition, EPA would
like to convene three focus groups as part of an effort to gather
feedback from stakeholders on the need for, and appropriate development
and promotion of, a curriculum for pre-service teachers on responsible
chemical management that can serve as a model for colleges and
universities.  

This supporting statement examines these information collections.  It
consists of Parts A and B.  Part A describes these collections,
including the need and use/utility of the information collected.  It
also describes respondent and Agency activities and estimates the total
annual hour and cost burden to respondents and the Agency under the
collections.  Part B addresses additional issues relating to data
collection, analysis and reporting under the SC3 Survey.

Following is a further description of the information collections.

SC3 Survey

One of the ways that EPA accomplishes its goals under SC3 is by
partnering with organizations that volunteer to assist schools in the
management of the schools’ chemicals and the removal of schools’
chemical waste.  There are currently eleven Partners.  

EPA intends to conduct a voluntary survey of Partners each year to learn
about their experiences and needs under the Program.  EPA has created
two survey forms, as follows:

Initial Survey.  This survey form will be completed by Partners who are
participating in the SC3 Survey for their first time.  It is designed to
give EPA a general idea of a Partner’s background, accomplishments,
and needs under SC3.  The survey is completed only for the first year of
a Partner’s participation in the SC3 Survey.

Annual Update.  Partners will complete an Annual Update in each
subsequent year of their partnership.  The Annual Update is designed to
describe a Partner’s accomplishments and needs since the previous
survey.

Partners can submit completed surveys by email, postal mail, special
delivery, or fax.

Focus Groups for Promoting Training for Pre-Service Teachers

EPA is interested in promoting the responsible management of chemicals
in K-12 schools.  To this end, EPA would like to hold three focus groups
as part of an effort to gather information about the extent to which
colleges and universities are teaching pre-service teachers about
responsible chemical management.  If EPA finds that a need exists to
promote pre-service teacher training on responsible chemical management,
EPA will gather feedback from the focus groups for the development
and/or promotion of a curriculum on responsible chemical management that
can serve as a model for colleges and universities. 

	Each focus group will consist of up to nine individuals from industry,
educational institutions (e.g., faculty, students), States, and Federal
agencies.  During the focus groups, EPA will raise questions and collect
feedback from focus group members.  

EPA will schedule the focus groups to coincide with conferences and
meetings that focus group members would otherwise attend.  This will
relieve them of the need to pay for travel and lodging to participate in
the focus group.

2.	NEED FOR AND USE OF THE COLLECTION

2(a)	Need and Authority for the Collection

Dangerous chemicals represent one of the critical environmental health
and safety issues that K-12 schools must address.  Accidental spills of
these chemicals can endanger students and staff, result in school days
lost, cost millions of dollars to clean up each year, and are, in many
instances, preventable. 

	The purpose of the SC3 Program is to promote chemical management
programs that remove outdated, unknown, or unneeded amounts of dangerous
or inappropriate chemicals from K-12 schools.  SC3 also promotes the
creation of policies and practices that prevent future accumulations of
chemicals and encourages responsible management

practices of chemicals used in schools.  These efforts aim to minimize
exposure to students and staff, thus improving the learning environment
and reducing school days lost.

Following is a description of why the information collections under SC3
are necessary.  

SC3 Survey

Following is a discussion of the information to be collected with the
SC3 Survey.  The discussion is organized according to Parts 1-3 of the
survey forms.  Under each part, EPA summarizes the information collected
and indicates why it is necessary.  Refer to the survey forms for the
specific questions.

Part 1: General Information on Partner

Information on how a Partner learned about SC3 and why it chose to join
the Program will help EPA learn which of its outreach activities are
working, who they are reaching, and Partners’ motivations for joining.
 This information is necessary for EPA to improve the Program (e.g.,
enhance its outreach efforts, encourage greater participation) and
communicate with others (e.g., about how Partners generally become aware
of the Program). 

Information on a Partner’s activities in supporting schools (e.g.,
previous involvement with schools prior to SC3), use of
contractors/consultants, and efforts to encourage others to join SC3
will help EPA to better understand its role under SC3, gauge Partner’s
level of experience/expertise in supporting schools, and assess
Partner’s satisfaction under the Program.  This information is
necessary for EPA to evaluate and improve the Program (e.g., develop
resources that are tailored to the Partner’s needs and level of
expertise, etc.) and communicate with others (e.g., about Partners’
efforts to encourage other organizations to join).

Information about the schools supported under SC3 helps EPA keep track
of the number of schools, students, and faculty affected by the Program.
 This information is necessary for EPA to assess the activities and
impacts being made under the Program.

Information on a Partner’s hours and dollars spent in providing
services and resources to schools helps EPA understand the level of
involvement of Partners and their resource needs.  This information is
necessary for EPA to identify ways to streamline activities and reduce
burdens associated with the Program, provide additional resources where
needed, and communicate with others about expenditures generally.

Part 2:  Description of Resources and Services Provided

Information on each of the services and resources provided by a Partner
(e.g., chemical inventories, trainings, waste removals, outreach), as
well as the number of schools, students, and staff in the schools, helps
EPA learn about the impacts being made by Partners and the number of
schools and people affected.  This information is necessary for EPA to
evaluate and improve the Program (e.g., to develop additional
guidances/tools to address specific Partner activities/needs, identify
needs of schools that are not being sufficiently addressed under the
Program), and communicate with others about the Program and the
Partner’s activities.

Information on the specific types of chemicals/wastes handled by
Partners (e.g., chemical inventories and cleanouts) helps EPA understand
the types of chemicals and safety hazards in schools.   This information
is necessary for EPA to identify and address the particular safety
hazards to Partners as well as to students and staff, identify methods
to minimize the presence of outdated/unneeded chemicals and accidents in
schools, and communicate with others (e.g., outreach to schools on
proper chemical/waste management and safety).

Information about a school’s experience with chemical inventories,
chemical management programs, training, and chemical removals prior to
participating in an SC3 partnership helps EPA assess the school’s
familiarity with these activities.  This information is necessary for
EPA to develop technical and other resources that are relevant to the
schools’ level of expertise and involvement, and to better understand
the types of schools that are involved in the Program.  

Part 3: Successes, Barriers, and Future Activities

Information on whether a Partner’s objectives and expectations under
the Program have been met will help EPA gauge Partners’ level of
satisfaction with the Program.  This information is necessary for EPA to
identify ways to address a Partner’s concerns and expectations more
effectively.

Information on a Partner’s most prohibitive barrier under the Program
will help EPA identify problems and difficulties that Partners are
having.  This information is necessary for EPA to help the Partner
overcome the barrier so it can be more productive.

Information on a Partner’s future plans regarding SC3 participation
will help EPA identify a Partner’s motivations and whether it will
continue being an active SC3 partner and in what capacity.  This
information is necessary for EPA to be able to anticipate its activities
in the future.  This information is also necessary for EPA to identify
the key factors influencing a Partner’s continued participation so
that EPA can address these factors if needed and can ensure the
Partner’s continued participation.

Information on a Partner’s successes and best practices will help EPA
identify activities that are effective under the Program.  This
information is necessary so that EPA can share lessons learned with
other Partners, to increase their own productivity.  The information can
also be shared with the general public to increase their understanding
of Partners’ activities.  

Information on a Partner’s suggestions for encouraging other
organizations to join SC3 and/or increase existing Partners’ efforts
under SC3 will help EPA learn about ways to increase participation and
accomplishments under the Program.  This information is necessary for
EPA to ensure the continued growth and success of the Program. 

Information on a Partner’s suggestions for improving the resources
available at the SC3 web site is necessary for EPA to continually
improve and expand the resources to address Partners’ changing needs.

Focus Groups for Promoting Training for Pre-Service Teachers

	EPA believes that a need exists to promote the training of pre-service
teachers in responsible chemical management in colleges and
universities.  EPA believes that training pre-service teachers before
they enter the classroom about responsible chemical management is
important because it will enable them to practice good chemical
management themselves; teach their own students about responsible
chemical management; and ensure a safe learning environment for their
students as well as a safe teaching environment for themselves.

EPA will convene three focus groups as part of an effort to gather input
from individuals knowledgeable about responsible chemical management. 
Participants will be asked to provide feedback, for example, on whether
there is a need for a curriculum on responsible chemical management and
how college and university programs can be strengthened in this regard. 
They also will provide ideas on how EPA can create an effective
curriculum (e.g., what topics and skills to address), if needed, or
promote existing curricula.  This feedback is necessary for several
reasons.  For example, EPA needs to hear from the representatives of
post-secondary educational institutions (e.g., faculty, administrators)
to find out their preferences and needs for the curriculum.  Their
upfront involvement is critical so that EPA understands their
expectations and desires and can respond accordingly.  Feedback from
representatives of K-12 schools (e.g., teachers) is needed so that EPA
understands the classroom conditions and needs of teachers in K-12
schools.  Feedback from representatives of State accrediting boards is
necessary so that EPA understands how to get existing or new curricula
accredited.  Feedback from industry and others is necessary for EPA to
hear about their suggestions for topics and skills to teach pre-service
teachers (e.g., best industry practices for managing chemicals safely). 
Refer to the script of the focus groups for additional information on
the questions to be raised.

2(b)	Practical Utility and Users of the Data

Following is a description of the practical utility and users of the
information collected under SC3.  

SC3 Survey

Following is a discussion of the information to be collected under the
SC3 Survey.  The discussion is organized according to Parts 1-3 of the
survey forms.  Under each part, EPA summarizes the information collected
and describes its utility and users.  Refer to the survey forms for the
specific questions.

Part 1: General Information on Partner

Information on how a Partner learned about SC3 and why it chose to join
the Program will be used by EPA to learn which of its outreach
activities are working, who they are reaching, and Partners’
motivations for joining.  EPA will use this information to improve the
Program and communicate with others. 

Information on a Partner’s activities in supporting schools (e.g.,
previous involvement with schools prior to SC3), use of
contractors/consultants, efforts to encourage others to join SC3 will be
used by EPA to understand its role under SC3, gauge Partner’s level of
experience/expertise in supporting schools, and assess Partner’s
satisfaction under the Program.  EPA will use the information to
evaluate and improve the Program and communicate with others. 

Information on the schools supported under SC3 will be used by EPA to
keep track of the number of schools, students, and faculty affected
under the Program.  EPA will use this information to assess the
activities and impacts being made under the Program.

Information on a Partner’s hours and dollars spent in providing
services and resources to schools will be used by EPA to evaluate the
level of involvement of Partners and their resource needs.  EPA will use
this information to identify ways to streamline activities and reduce
burdens under the Program, provide additional resources where needed,
and communicate with the public about potential expenditures.

Part 2:  Description of Resources and Services Provided

Information on each of the services and resources provided by a Partner
(e.g., chemical inventories, trainings, waste removals, outreach), as
well as the number of schools, students, and staff in the schools, will
be used by EPA to learn about the impacts being made by Partners.  

Information on the specific types of chemicals/wastes handled by
Partners will be used by EPA to understand the types of chemicals and
safety hazards in schools.   EPA will use this information to identify
and address safety concerns (e.g., safety hazards to Partners as well as
to students and staff), identify methods to minimize the presence of
outdated/unneeded chemicals and accidents in schools, and communicate
with the public.

Information about a school’s experience with chemical inventories,
chemical management programs, training, and removals prior to SC3 will
be used by EPA to assess the school’s familiarity with these
activities.  EPA will use this information to develop technical and
other resources that are relevant to the school’s level of expertise
and involvement.

Part 3: Successes, Barriers, and Future Activities

Information on whether a Partner’s objectives and expectations related
to the Program have been met will be used by EPA to gauge its level of
satisfaction with the Program.  EPA may identify ways to address
Partner’s concerns and expectations more effectively.

Information on a Partner’s most prohibitive barrier under the Program
will be used by EPA to identify problems and difficulties that Partners
are facing.  EPA may be able to help the Partner overcome the barrier.

Information on a Partner’s future plans related to SC3 participation
will be used by EPA to identify Partner’s motivations and assess
whether it will continue as an SC3 Partner and in what capacity.  EPA
will use this information to be able to anticipate its activities in the
future.  EPA will also identify the key factors influencing a
Partner’s continued participation so that the Agency can address these
factors if needed and ensure the Partner’s continued participation.

Information on a Partner’s successes and best practices will be used
by EPA to identify methods that are most effective.  EPA will share
lessons learned with Partners to help them increase their productivity. 
The information can also be shared with the general public to show them
Partners’ activities.  

Information on a Partner’s suggestions for encouraging other
organizations to join SC3 and/or increase existing Partners’ efforts
will be used by EPA to learn about ways to increase participation and
accomplishments under the Program.  EPA will use this information to
ensure the continued growth and success of the Program. 

Information on a Partner’s suggestions for improving the resources
available at the SC3 web site will be used by EPA to improve these
resources.  EPA will use this information to continually improve and
expand these resources to address Partners’ changing needs.

Focus Groups for Promoting Training for Pre-Service Teachers

EPA will gather feedback from the focus groups to learn how college and
university pre-service teacher programs on responsible chemical
management can be promoted.  EPA will use this feedback to assess the
need for a curriculum on responsible chemical management that can serve
as a model for colleges and universities.  If focus group feedback
indicates that a curriculum is needed, EPA will use this feedback to
develop a curriculum on responsible chemical management that addresses
the expectations and requirements of key stakeholder groups.  

3.	NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA	

3(a)	Nonduplication

None of the information requested under this ICR is duplicative with any
information currently available to the Federal government.

3(b)	Public Notice

In compliance with the Paperwork Reduction Act of 1995, EPA issued a
public notice in the Federal Register on June 18, 2008 (73 FR 34731). 
The public comment period extended through August 18, 2008.  EPA did not
receive any comments. 

3(c)	Consultations

In late June to mid-July of 2008, EPA conducted a pilot test of the
Initial Survey.  EPA emailed the draft survey instrument and a Feedback
Form for completion by eight Partners.  The Feedback Form asked for
Partners’ comments on the clarity and user-friendliness of the survey
questions, how the questions could be improved, and their burden hours
for completing the survey.  

EPA received completed surveys from four Partners and Feedback Forms
from two.  See the table below for Partners that participated in the
pilot test.  EPA reviewed Partners’ completed surveys and feedback and
followed up with three of them to get clarification on some of their
suggestions and concerns.

Following this, EPA revised the survey to address the suggestions and
concerns identified by Partners as well as by EPA.  Specifically, EPA
clarified specific survey questions that Partners found confusing or
that otherwise led to response errors.  EPA also simplified questions
that may have been too burdensome.  In addition, EPA modified some
questions to give Partners greater flexibility in how to provide a
response.  

EPA also examined Partners’ burden for completing the survey, based on
the two Feedback Forms received.  One Partner spent five minutes and the
other spent 20 minutes completing the survey.  This information was
helpful to EPA.  In the end, however, EPA has decided to estimate a
higher burden in this ICR (i.e., 1 hour for the Initial Survey and 45
minutes for the Annual Update) to account for the potentially wide
variation in Partner activities under the Program.  See Section 6(d) of
Part A of this supporting statement for these burden estimates.

Participants in SC3 Survey Pilot Test

Name of Partner Organization	Name of Contact Person

American Chemistry Council (ACC)	Tomaysa Sterling

BG Products, Inc. (BG)	Kolin Anglin

Continental Concrete Company	Frank Salter

Synthetic Organic Chemical Manufacturers Association (SOCMA)	James
Hinebaugh

3(d)	Effects of Less Frequent Collection

SC3 Survey

	Partners will be asked to participate in the SC3 Survey annually.  This
is the lowest frequency that is appropriate, because there is a
reasonable expectation of significant change in Partners’ responses
from year to year.  The Annual Update is designed to request information
on a Partner’s activities and needs since the previous survey. 
Because EPA expects a number of Partners to be highly active each year
on a diverse range of activities (e.g., chemical removals, trainings,
etc.), EPA anticipates that their responses could differ significantly
each year.  A less frequent collection schedule would not capture these
differences effectively.

	In addition, a less frequent collection schedule would place a greater
burden on Partners, because they would have to keep records of their
activities and accomplishments for a longer period of time.  An annual
frequency is an appropriate length of time for Partners to be able to
readily recollect and recount their experiences.

Focus Groups for Promoting Training for Pre-Service Teachers

	EPA will convene three focus groups to gather input for a curriculum on
responsible chemical management for pre-service teachers in colleges and
universities.  Three focus groups will be needed to gather information
from the wide range of individuals and organizations that have
experiences and ideas to share (e.g., State and Federal regulators,
industry, educators, and students).  Three focus groups will also enable
EPA to examine trends from one focus group to the next (e.g., comments
and themes that are raised by different stakeholder groups).  In
addition, three focus groups will allow EPA to gather feedback as it
implements its approach, so that comments are collected and addressed
throughout the process.  

3(e)	General Guidelines

This ICR adheres to the guidelines stated in the Paperwork Reduction Act
of 1995, OMB’s implementing regulations, EPA’s ICR Handbook, and
applicable OMB guidance.

3(f)	Confidentiality

Participation in the information collections in this ICR would be
voluntary.  EPA does not expect to deem any information collected to be
Confidential Business Information (CBI).  If a claim of CBI is asserted,
EPA will manage that information in accordance with EPA's provisions on
confidentiality.  40 CFR Part 2, Subpart B establishes EPA's general
policy on the public disclosure of information and procedures for
handling CBI claims.

3(g)	Sensitive Questions 

	

No questions of a sensitive nature will be asked in the information
collections in this ICR.

4.	THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a)	Respondents and NAICS Codes

The following is a list of all North American Industry Classification
System (NAICS) codes at the 2-digit level.  An entity from any sector
may volunteer to participate under SC3 (e.g., as a Partner).  

NAICS Codes of Potentially Affected Industries

Industry Sectors	

NAICS Codes

Agriculture, Forestry, Fishing and Hunting	11

Mining, Quarrying, and Oil and Gas Extraction	21

Utilities	22

Construction	23

Manufacturing	31-33

Wholesale Trade	42

Retail Trade	44-45

Transportation and Warehousing	48-49

Information	51

Finance and Insurance	52

Real Estate and Rental and Leasing	53

Professional, Scientific, and Technical Services	54

Management of Companies and Enterprises	55

Administrative and Support and Waste Management and Remediation Services
56

Educational Services	61

Health Care and Social Assistance	62

Arts, Entertainment, and Recreation	71

Accommodation and Food Services	72

Other Services (except Public Administration)	81

Public Administration	92

4(b)	Information Requested

SC3 Survey

To evaluate the current state of the SC3 Program and determine what the
future direction should be, EPA intends to conduct a voluntary survey of
its Partners to gather information on their activities and the results
of their work under the Program.  The SC3 Survey would be conducted
annually.

EPA has created two survey forms, as follows:

Initial Survey.  This survey form will be completed by Partners who are
participating in the SC3 Survey for their first time.  It is designed to
give EPA a general idea of a Partner’s background, accomplishments,
and needs under SC3.  The survey is completed only for the first year of
a Partner’s participation in the SC3 Survey.

Annual Update.  Partners will complete an Annual Update in each
subsequent year of their partnership.  The Annual Update is designed to
describe a Partner’s accomplishments and needs since the previous
survey.

Partners can submit completed surveys by email, postal mail, special
delivery, or fax.  After receiving the completed survey, EPA may follow
up with the Partner if needed (e.g., to resolve a data entry error).

	(i)	Data Items:

Information requested by Initial Survey and Annual Update: 

--	Company name, name of contact person, and contact person’s phone
number.

--	Date of submittal.

--	Part 1: General Information on Partner

How a Partner learned about SC3 and why it chose to join the Program
(Initial Survey only). 

Partner’s activities in supporting schools (e.g., previous involvement
with schools prior to SC3), use of contractors/consultants, efforts to
encourage others to join SC3.

Description of school(s) supported under SC3.

Partner’s hours and dollars spent in providing services and resources
to schools since joining the program.

- 	Whether Partner participates in other EPA Partnership Programs
(Initial Survey only).

--	Part 2: Description of Services and Resources Provided

Types of services and resources provided to schools (e.g., chemical
inventories, trainings, chemical cleanouts, outreach), as well as the
number of schools, students, and staff affected by each. 

Types of chemicals/wastes handled by Partners (e.g., chemical
inventories and removals).

School’s experience with chemical inventories, chemical management
programs, training, and chemical removals prior to its involvement in
SC3, and the improvements made by Partners.  

--	Part 3: Successes, Barriers, and Future Activities 

Whether a Partner’s objectives and expectations under the Program have
been met.

Partner’s most prohibitive barrier under the Program.	

Partner’s future plans under the Program.	

Partner’s success story and best practices under SC3. 

Partner’s suggestions for encouraging other organizations to join SC3
and/or increase existing Partners’ efforts under SC3 (Initial Survey
only). 

Partner’s suggestions for improving the resources available at the SC3
web site.

--	Worksheets 1-5.

 

	(ii)	Respondent Activities:

Complete and submit Initial Survey and respond to EPA’s follow-up
questions (for clarification purposes) if any; or 

Complete and submit Annual Update and respond to EPA’s follow-up
questions (for clarification purposes) if any.

Focus Groups for Promoting Training for Pre-Service Teachers

EPA is interested in promoting the responsible management of chemicals
in K-12 schools.  To this end, EPA would like to hold three focus groups
as part of an effort to gather information about the extent to which
colleges and universities are teaching pre-service teachers about
responsible chemical management.  If EPA finds that a need exists to
promote pre-service teacher training on responsible chemical management,
EPA will gather feedback from the focus groups for the development and
promotion of a curriculum on responsible chemical management that can
serve as a model for colleges and universities. 

Each focus group will consist of up to nine individuals representing
industry, educational institutions (e.g., educators, students), States,
and Federal agencies.  EPA will discuss questions with focus group
members and collect their feedback. 

EPA will schedule the focus groups to coincide with other meetings and
conferences that focus group members would otherwise attend.  This will
relieve the focus group members of the cost for travel or lodging for
the focus group.

(i)	Data Items:

Feedback requested by EPA:

--	Background/Context

-	Participants’ background and interest in pre-service teacher
training in responsible chemical management.

How pre-service teachers generally learn about responsible chemical
management.

Whether participants are aware of existing pre-service teacher trainings
in responsible chemical management.

--	Curriculum-Specific Questions

-	Elements included in existing responsible chemical management
training. 

- 	Best ways to present pre-service teacher training. 

-	Modifications needed, if any, to existing pre-service training. 

-	Typical State policies that would support pre-service teacher training
in responsible chemical management.

--	Barriers to Developing, Improving, and/or Instituting Pre-service
Teacher Training

-	Barriers to adding responsible chemical management training to
pre-service teacher course work.

-	Strategies that have been tried to overcome barriers to instituting
pre-service teacher training in responsible chemical management.

--	Promotion of Curriculum

-	Approaches that have successfully resulted in responsible chemical
management training being added to teacher course work.

-	Policies that would help create a recognition of need for colleges and
universities to provide pre-service teacher training on responsible
chemical management.

-	Approaches for promoting pre-service teacher training.

-	Approaches for incorporating a new concept into teacher
certification/licensure.

-	Role of the SC3 Partners in promoting pre-service teacher training.

-	Approaches for piloting the curriculum. 

	(ii)	Respondent Activities:

Attend focus group and provide feedback.

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

5(a)	Agency Activities

SC3 Survey

EPA will review and keep records of completed surveys and follow up with
Partners if needed (e.g., to resolve an error in the survey).

	Focus Groups for Promoting Training for Pre-Service Teachers

EPA will attend the focus groups and document the feedback of
participants.

5(b)	Collection Methodology and Management

SC3 Survey

EPA will email the surveys to Partners and ask them to submit completed
surveys by email, regular mail, postal mail, or fax by the due date
indicated on the survey form.  EPA will keep completed surveys in an
electronic format (e.g., on hard drive) and/or as hardcopies in file
cabinets.  Refer to Part B of this supporting statement for additional
information on EPA’s data collection and management.

	Focus Groups for Promoting Training for Pre-Service Teachers

EPA will attend the focus groups and take notes of participant feedback.
 EPA will provide a facilitator to encourage discussion and make sure
everyone’s feedback is obtained.  EPA will keep the notes in an
electronic format (e.g., on hard drive) and/or as a hardcopies in file
cabinets.

5(c)	Small Entity Flexibility

The SC3 Program is voluntary.  Participation in the SC3 Survey and focus
groups also is voluntary.  Individuals will participate only if they
expect an overall benefit by doing so.  

	SC3 Survey

EPA has designed the survey forms to minimize burden while obtaining
sufficient and accurate information.  This has included a pilot test,
which asked for feedback on difficulties and burdens in completing the
survey, as well as suggestions for improving the survey format and
questions.  EPA believes this has resulted in a user-friendly survey.

	Focus Groups for Promoting Training for Pre-Service Teachers

EPA will conduct the focus groups to minimize burden on both large and
small entities.  For example, EPA will schedule the focus groups to
coincide with other meetings and conferences that focus group members
would otherwise attend.  This will minimize their costs for
participating in the focus group.

	5(d)	Collection Schedule

SC3 Survey

The SC3 Survey will be conducted annually.  

Focus Groups for Promoting Training for Pre-Service Teachers

Three focus groups will be conducted during the three-year life of this
ICR.  EPA will document participants’ feedback at the focus groups.

6.	ESTIMATING THE HOUR AND COST BURDEN OF THE COLLECTION

6(a)	Estimating Respondent Burden Hours

Exhibit 1 estimates the annual respondent burden hours for information
collection activities associated with the SC3 Program. 

6(b)	Estimating Respondent Costs

Exhibit 1 estimates the annual respondent costs for information
collection activities associated with the SC3 Program.  Specific cost
assumptions are discussed below.

(1)	Labor Costs 

The respondent labor costs in Exhibit 1 were obtained from the “May
2006 National Occupational Employment and Wage Estimates.” The
estimates can be found in the Occupational Employment Statistics, U.S.
Department of Labor, U.S. Bureau of Labor Statistics.  EPA updated the
2006 wage estimates to 2008 wage levels using the employment cost index.
 EPA then multiplied the rates by the labor cost fringe benefits and
overhead factor of 1.4845.  Based on this, EPA estimates an average
loaded respondent hourly labor rate of $64.63 for legal staff, $69.61
for managerial staff, $45.44 for technical staff, and $22.99 for
clerical staff.

(2)	Capital Costs

Capital costs usually include any produced physical good needed to
provide the needed information, such as machinery, computers, and other
equipment.  EPA does not anticipate that respondents will incur capital
costs in carrying out the information collection requirements covered in
this ICR.

(3)	Operation & Maintenance Costs

	O&M costs are defined by the PRA as the recurring costs associated with
a collection of information (e.g., postage, photocopying, etc.).  EPA
expects Partners to use their existing email capabilities to submit
completed surveys to EPA.  However, EPA also has included postage costs
($0.42/submittal) because Partners may submit hardcopy materials by
regular mail (e.g., hazardous waste manifests).

6(c)	Estimating Agency Hour and Cost Burden

Exhibit 2 presents EPA’s hour and cost burden under the information
collections in this ICR.  It reflects that EPA will take 15 minutes to
review and keep records of each survey.  It also reflects that two EPA
staff will attend each focus group, and each will last three hours. 
This equates to six hours for the Agency per focus group.

Unloaded hourly wage rates for EPA’s activities were taken from the
2008 General Schedule and Locality Pay Tables from the U.S. Office of
Personnel Management.  EPA then multiplied the rates by the labor cost
fringe benefits and overhead factor of 1.6.  Based on this, EPA applied
the following average loaded hourly wage rates for government labor:
$76.67 per hour for legal staff, $70.46 per hour for managerial staff,
$59.63 per hour for technical staff, and $22.82 per hour for clerical
staff.

6(d)	Estimating the Annual Respondent Universe and Total Hour and Cost
Burden

SC3 Survey

There are currently eleven Partners in the SC3 Program.  In addition,
EPA expects that eleven new Partners will join SC3 each year.  This
estimate is based on EPA’s experience working with existing and
prospective Partners over the past year.

EPA estimates that it will take a Partner one hour, on average, to
complete and submit the Initial Survey and respond to EPA’s follow-up
questions if any.  EPA estimates that a Partner will take less time to
complete and submit the Annual Update because it contains fewer
questions.  In addition, Partners will be more familiar with the
instructions and information needs than the first time.  Because of
these reasons, EPA estimates that it will take a Partner 45 minutes, on
average, to complete and submit the Annual Update and respond to EPA’s
follow-up questions, if any, in each subsequent year.

The table below shows the number of Partners expected to participate in
the SC3 Survey in each of the three years of the ICR.  It shows that:

In the first year of the ICR, EPA estimates that the eleven existing
Partners will complete the Initial Survey, as well as the eleven new
Partners expected to join the Program during the year.  

In the second year, EPA estimates that the 22 existing Partners will
complete the Annual Update.  In addition, eleven new Partners will
complete the Initial Survey.

In the third year, EPA estimates that the 33 existing Partners will
complete the Annual Update.  In addition, eleven new Partners will
complete the Initial Survey.

Based on these assumptions, the table shows the average annual number of
Partners estimated to complete the survey forms during the three-year
life of this ICR (i.e., the total number of Partners divided by three
years).  Specifically, it shows that, on average each year, 15 Partners
will complete the Initial Survey and 18 Partners will complete an Annual
Update.  

Partners	Annual Number of Partners	Average Annual

Number of Partners*

	Year 1	Year 2	Year 3

	Partners that complete Initial Survey	22	11	11	15

Partners that complete Annual Update	0	22	33	18

Total	22	33	44	33

* Total number of Partners in Years 1-3 divided by three years (includes
rounding).

EPA used the average annual number of respondents, along with the burden
estimates described above, to estimate the average annual burden to
respondents.  Specifically, EPA estimates that 15 Partners will take one
hour to complete the Initial Survey and 18 Partners will take 45 minutes
to complete an Annual Update on average each year.  

These assumptions are reflected in Exhibit 1. 

Focus Groups for Promoting Training for Pre-Service Teachers 

EPA intends to hold three focus groups during the three-year period of
this ICR. EPA estimates that each focus group will consist of nine
individuals representing industry, educational institutions (e.g.,
educators, students), and government agencies.  At the focus groups, EPA
will discuss questions with focus group members and collect their
feedback.  

EPA will schedule the focus groups to coincide with other meetings and
conferences that focus group members will likely attend.  This will
relieve the focus group members of the cost for travel or lodging for
the focus group.

EPA has annualized the number of focus groups over the three-year life
of this ICR, to estimate that one focus group will be held annually on
average.  EPA estimates that each focus group will last three hours.

These assumptions are reflected in Exhibit 1.

6(e)	Bottom-Line Hour and Cost Burden

(1)	Respondent Tally

Exhibit 1 shows that the bottom-line annual respondent hour and cost
burden is estimated to be 56 hours and $2,910.  The bottom-line burden
to respondents over three years is estimated to be 168 hours and $8,730.

(2)	Agency Tally

Exhibit 2 shows that the bottom-line annual Agency hour and cost burden
is estimated to be 14 hours and $900.  The bottom-line burden to the
Agency over three years is estimated to be 42 hours and $2,700. 

6(f)	Reasons for Change In Burden

This is a new ICR.  As shown in Table 2, EPA estimates that the
collections would result in 56 hours to respondents annually.  

6(g)	Public Burden Statement

The annual public reporting burden for the SC3 Survey is estimated to
range from 45 minutes to one hour per respondent.  This includes time to
complete and submit the survey and respond to EPA’s follow-up
questions, if any.  There is no recordkeeping burden.

The annual public reporting burden for the focus groups is estimated to
be three hours per respondent.  This includes time to attend and
participate in the focus group.  There is no recordkeeping burden.

	Burden means the total time, effort, or financial resources expended by
persons to generate, maintain, retain, or disclose or provide
information to or for a Federal agency.  This includes the time needed
to review instructions; develop, acquire, install, and utilize
technology and systems for the purposes of collecting, validating, and
verifying information, processing and maintaining information, and
disclosing and providing information; adjust the existing ways to comply
with any previously applicable instructions and requirements; train
personnel to be able to respond to a collection of information; search
data sources; complete and review the collection of information; and
transmit or otherwise disclose the information.  An agency may not
conduct or sponsor, and a person is not required to respond to, a
collection of information unless it displays a currently valid OMB
control number.  The OMB control numbers for EPA's regulations are
listed in 40 CFR part 9 and 48 CFR chapter 15.

To comment on the Agency's need for this information, the accuracy of
the provided burden estimates, and any suggested methods for minimizing
respondent burden, including the use of automated collection techniques,
EPA has established a public docket under Docket ID Number
EPA-HQ-RCRA-2008-0330, which is available for online viewing at
www.regulations.gov, or in person viewing at the Resource Conservation
and Recovery Act (RCRA) Docket in the EPA Docket Center (EPA/DC), EPA
West, Room 3334, 1301 Constitution Avenue, NW, Washington, D.C.  The EPA
Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m.,
Monday through Friday, excluding legal holidays.  The telephone number
for the Reading Room is (202) 566-1744, and the telephone number for the
Resource Conservation and Recovery Act (RCRA) Docket is 202-566-0270. 
An electronic version of the public docket is available at
http://www.regulations.gov.  This site can be used to submit or view
public comments, access the index listing of the contents of the public
docket, and to access those documents in the public docket that are
available electronically.  When in the system, select "search," then key
in the Docket ID Number identified above.  Also, you can send comments
to the Office of Information and Regulatory Affairs, Office of
Management and Budget, 725 17th Street, NW, Washington, D.C. 20503,
Attention: Desk Officer for EPA.  Please include the EPA Docket ID
Number EPA-HQ-RCRA-2008-0330 and OMB Control Number 2050-New in any
correspondence.

Exhibit 1*                                                             
                                                                        
                                                                        
                                                                        
                                                                        
                         Estimated Annual Respondent Hour and Cost
Burden - SC3 Survey





 	Hours and Costs Per Respondent Activity	Total Hours and Costs

Information Collection Activity	Legal	Managerial 	Technical	Clerical
Labor Hours/Activity	Labor Costs/Activity	Capital Costs	O&M Costs	No. of
Respond./   Activities	Total Hours/Year	Total Cost/Year

	$64.63 	$69.61 	$45.44 	$22.99 







	SC3 Survey

Complete and submit Initial Survey and respond to EPA's follow-up
questions if any	0.15	0.15	0.50	0.20	1.00	$47.45	$0.00	$0.42	15	15
$718.05

Complete and submit Annual Update and respond to EPA's follow-up
questions if any	0.10	0.10	0.40	0.15	0.75	$35.05	$0.00	$0.42	18	14
$638.46

Focus Groups for Promoting Training for Pre-Service Teachers

Attend focus group and provide feedback	0.00	1.50	1.50	0.00	3.00	$172.57
$0.00	$0.00	9	27	$1,553.13

Total 	varies	varies	varies	varies	varies	varies	$0.00	varies	varies	56
$2,909.64

* Exhibit includes rounding.



Exhibit 2*                                                              
                                                                        
                                                                        
                                                                        
                          Estimated Annual Agency Hour and Cost Burden -
SC3 Survey





 	Hours and Costs Per Agency Activity	Total Hours and Costs

Information Collection Activity	Legal	Managerial 	Technical	Clerical
Labor Hours/ Activity	Labor Costs/ Activity	Capital Costs	O&M Costs	No.
of Agency Activities	Total Hours/ Year	Total Cost/ Year

	$76.67 	$70.46 	$59.63 	$22.82 







	SC3 Survey

Review and keep records of completed surveys and follow up with Partners
if needed	0.00	0.05	0.20	0.00	0.25	$15.45	$0.00	$0.00	33	8	$509.85

Focus Groups for Promoting Training for Pre-Service Teachers

Attend focus group and document feedback	0.00	1.50	1.50	0.00	3.00
$195.14	$0.00	$0.00	2	6	$390.28

Total 	0.00	varies	varies	0.00	varies	varies	$0.00	$0.00	varies	14
$900.13

* Exhibit includes rounding.



PART B OF SUPPORTING STATEMENT

1. 	Survey Objectives, Key Variables, And Other Preliminaries

The purpose of the SC3 Program is to promote chemical management
programs that remove outdated, unknown, or unneeded amounts of dangerous
or inappropriate

chemicals from K-12 schools.  SC3 also promotes the creation of policies
and practices that prevent future accumulations of chemicals and
encourages responsible management

practices of chemicals used in schools.  These efforts aim to minimize
exposure to students and staff, thus improving the learning environment
and reducing school days lost.

Under SC3, EPA partners with companies that agree to work directly with
K-12 schools to remove their chemical wastes and otherwise improve
chemical/waste management.  EPA has developed two survey forms to learn
about Partners’ experiences and needs under the Program: an Initial
Survey form (to be completed by a Partner in its first year of
participation in the SC3 Survey) and an Annual Update (to be completed
in each subsequent year of its partnership).  This is a census of
Partners.  There are currently 11 Partners.  

1(a)  	Survey Objectives

	

	The SC3 Survey has four main objectives: 

Collect information on the Partner’s reasons for joining the SC3
Program and its future plans.  

Identify the activities of Partners under the SC3 Program and how many
schools, students, and staff are affected.

Identify resources needed by Partners to accomplish SC3 goals.  

Collect lessons learned from Partners on what has worked and what has
not worked under the Program, so this information can be shared with
others.  

Refer to Section 2(d) of Part B of this supporting statement for a
description of how these survey objectives are achieved by the
information collected by the survey.

1(b)  	Key Variables

The SC3 Survey is designed to collect information from Partners on their
experiences and needs under SC3 during the past year or longer.  A key
variable, therefore, is the extent to which a Partner is able to
remember and/or access records in order to report its activities
performed during this time period.  Partners are free to draw on any
available information to do so (e.g., records kept as a standard
business practice such as invoices and records kept in accordance with
existing regulations, such as hazardous waste manifests).  Each
Partner’s memory and records will vary, e.g., in quality and detail. 
Based on the pilots, EPA is confident that Partners will be able to
complete the survey effectively, e.g., based on information that is kept
as a standard business practice and/or in accordance with existing
regulations.

1(c)  	Statistical Approach

This section is not applicable to the SC3 Survey because EPA does not
intend to use any statistical methods in the collection or analysis of
survey data.  Refer to Section 5(b) of Part B of this supporting
statement for additional information.

1(d)  	Feasibility

	EPA intends to email the survey forms to Partners to complete and
return.  The surveys have been prepared in the Microsoft Word program. 
Partners must open the file in Word to complete the survey
electronically.  The primary feasibility issue is whether a Partner has
access to the Internet and the Word program.  If not, this would limit
the feasibility of the emailed Word file for the Partner.  

A Partner without Internet access and/or the Word program can request a
hardcopy of the survey, which can be completed and returned by fax,
regular mail, or special delivery.

2. 	Survey Design

	2(a) 	Target Population and Coverage

	The SC3 Survey is a census of Partners.  There are currently 11
Partners.  EPA expects this number to increase over the coming years as
more organizations learn about the benefits of the SC3 Program and join.

2(b)	Sample Design

This section is not applicable to the SC3 Survey because EPA will not
perform any sampling.

2(c)	Data Quality

In designing the SC3 Survey, EPA considered potential data quality
issues that could be associated with collected data.  These are
discussed below.

(i)	Response Rates 

EPA has considered both unit (survey) and item (question) non-response. 
EPA estimates that the unit response rate will be at least 50% to 60%
for the SC3 Survey.  This estimate is based on EPA’s pilot test of the
survey, in which 50% of participants completed and submitted a survey
form.  EPA expects, however, that the response rate for the full-scale
survey will be higher.  First, EPA intends to increasingly promote the
survey to new and existing Partners (e.g., by discussing the importance
of the survey in communications with Partners).  In addition, EPA
expects Partners’ participation to increase as they gain more
experience with the survey and the SC3 Program generally and learn
convenient ways to keep track of their activities and accomplishments. 
Finally, EPA will use the follow-up methods described in Section 4(b) to
maximize response rates. 

To minimize item non-response, EPA has carefully reviewed the survey
questions to ensure that they are easy to understand and use familiar
terms; are formatted in a logical sequence; and request data that are
readily available to Partners.  In this manner, EPA expects to minimize
inaccurate or incomplete responses that can occur due to
misinterpretations and the unintentional skipping of questions. 
Additionally, a cover letter will provide the name of a contact person,
email address and phone number to assist Partners, if needed.  

After receipt of the completed surveys, EPA will conduct follow-up with
respondents as needed (e.g., to address missing data).  Refer to Section
5(a) of Part B of this supporting statement for information on EPA’s
data review procedures when completed surveys are received.

(ii)	Data Entry Errors 

EPA has designed the survey forms to be user friendly for Partners.  The
survey forms are protected Microsoft Word files, which means that
Partners will be able to electronically enter data only into the
specified fields of the forms.  They will not be able to modify the
forms in any other way.  This will simplify their data entry and
minimize errors.  

In addition, the survey includes a number of tables with pull-down
menus.  This will simplify Partner responses and minimize the need to
enter data.  

Finally, the survey forms encourage Partners to respond to some
questions by providing existing documentation instead of entering
information into the forms, such as hazardous waste manifests or
shipping papers.  This will reduce burden and minimize data entry
errors.

After receipt of the completed surveys, EPA will conduct follow-up with
respondents as needed (e.g., to address errors).  Refer to Section 5(a)
of Part B of this supporting statement for information on EPA’s data
review procedures when completed surveys are received.

(iii)	Biased Responses

EPA has considered the possibility for biased responses to the survey,
which could result from questions that are worded in such a way that a
particular answer is favored over others.  EPA has carefully phrased
each question so that it does not lead to biased responses.  For
example, EPA conducted a pilot test of the survey instrument and
contacted pilot test participants to discuss their responses.  EPA
examined whether they were providing the requested information without
bias or misunderstanding.  If any bias, misunderstanding, or other
problem was detected, EPA revised the question as appropriate.

	

	EPA notes that some Partners may elect not to submit a survey in a
given year for a variety of reasons and that Partners that do submit a
survey may be those with a more compelling reason to do so.  For
example, the more active Partners may be more inclined to complete the
survey in order to demonstrate their achievements and the less active
Partners may be less inclined to complete the survey because they have
fewer achievements to demonstrate.  Such factors could lead to a
self-selection bias.  However, EPA does not believe this is a concern. 
EPA is not performing extrapolations or other data modeling, so there is
not a need for representative data.  Rather, EPA will provide only a
straightforward presentation of the information collected.  In addition,
EPA will attempt to maximize response rates by using the procedures
described in Section 4(b) of Part B of this supporting statement.

(iv)	False Information Provided by Respondents

EPA is in periodic, informal contact with Partners during the year and
has generally a good idea of the level and types of a Partner’s
activity and accomplishments.  If EPA has questions about a Partner’s
survey results, EPA will contact it for clarification.  

2(d)	Questionnaire Design

	The Initial Survey and Annual Update were designed to be as unambiguous
and straightforward as possible.  Survey questions include simple
instructions on how to provide a response.  Five worksheets are included
to assist Partners provide the requested information.  A cover letter
provides an EPA contact person’s name, phone number and email address
if assistance is needed.  

Each survey form is organized into three parts.  Each part addresses one
or more of the survey objectives identified in Section 1(a) of Part B of
this supporting statement.  Following is a brief discussion of how these
survey objectives are addressed by the information collected on the
survey forms.

Part 1: General Information on Partner.  This part of the survey
addresses Objectives 1 and 2.  It collects information on, among other
things, the Partner’s reasons for joining the SC3 Program.  It also
collects information on the number of schools, students, and staff that
were affected by the Partner’s activities under SC3 collectively.  

Part 2: Description of Services and Resources Provided.  This part of
the survey address Objectives 2 and 3.  It collects information on each
type of service and resource that a Partner has provided under SC3.  It
also collects information on the number of schools, students, and staff
that were affected by each service and resource provided (e.g., chemical
inventories, chemical cleanouts, etc.).  

Part 3: Successes, Barriers, and Future Activities.  This part of the
survey addresses Objectives 1, 3 and 4.  It collects information on a
Partner’s future activities (e.g., its anticipated plans under SC3
over the coming years).  It collects information on resources needed by
Partners to accomplish SC3 goals (e.g., what types of incentives EPA can
provide to encourage Partner accomplishments and what improvements can
be made to resources at the SC3 web site).  It also collects lessons
learned from Partners on what has worked (e.g., success stories) and
what has not worked under the Program (i.e., barriers it has encountered
under the Program).

3. 	Pretests And Pilot Tests

In late June to mid-July of 2008, EPA conducted a pilot test of the
draft SC3 Survey.  EPA emailed the draft survey instrument and a
Feedback Form for completion by eight Partners.  The Feedback Form asked
for Partners’ comments on the clarity and user-friendliness the survey
questions, how the questions could be improved, and their burden hours
for completing the survey.  EPA reviewed the completed surveys and
Feedback Forms, followed up with participants to get additional
feedback, and then revised the survey to address their and EPA’s
suggestions and concerns.

 

Refer to Section 3(c) of Part A of this supporting statement for
additional information on the pilot test.

4. 	Collection Methods And Follow-up

4(a)  	Collection Methods

	Each year, EPA will email the survey forms to Partners well in advance
of the due date for submittal.  A cover letter describes the purpose of
the survey, indicates the due date for submittal, and describes
submittal methods, including email, fax, regular mail, and special
delivery.  It also includes an EPA contact person’s name, phone number
and email address if assistance is needed.  

4(b)		Survey Response And Follow-up

	EPA will perform follow-up activities, described below, after the
surveys are emailed out, in order to increase response rates:

Email a first reminder a few weeks prior to the due date.

On the due date, email a second reminder to those who have not
responded.

Within two or three weeks after the due date, email a third reminder to
those who have not responded and/or call them directly.

5. 	Analyzing And Reporting Survey Results

5(a)	Data Preparation

EPA will take the following steps to identify and resolve quality
problems in the survey data:

When a survey is received, EPA will review it initially for completeness
and quality.  EPA will look for errors, including the following:

--	Data entry errors.  EPA will detect these errors by looking for 1)
conflicting/inconsistent responses, 2) typographical errors, and 3)
other noticeable errors.

--	Incomplete/missing data.  EPA will detect these errors by looking for
gaps in completed surveys (i.e., missing responses that logically should
be completed based on other responses in the survey or what is otherwise
known about the Partner).

--	Misinterpreted questions.  EPA will detect these errors by looking
for responses that do not respond logically to the survey question
(e.g., non sequiturs).

If there are simple errors (e.g., typographical errors), EPA may resolve
them on its own.

If there are errors or other data quality problems that EPA cannot
resolve on its own, it will contact the respondent for resolution before
processing the data.  

5(b)	Data Analysis and Reporting

After resolving the data quality problems identified above, EPA intends
to use the information as follows.  Refer to Section 2(a) and 2(b) of
Part A of this supporting statement for additional information on uses
of the survey responses.

(i) 	To Examine Survey Data Internally and Make Improvements to the SC3
Program  

EPA may examine survey responses, for example, on how Partners became
aware of the SC3 Partner Program (see Question 1.1 of the Initial
Survey).  Survey data may be entered into a spreadsheet or word
processing program (e.g., MS Word), and reviewed for data entry errors. 
EPA may then examine and compare the different ways Partners learned
about the Program (e.g., via SC3 web site, trade organizations, etc.) to
identify the most and least prevalent ways.  This information could be
helpful in assessing the most and least effective ways to reach
prospective organizations to increase participation under SC3.  It might
also be helpful in assessing existing communication methods that could
be improved.  

(ii)	To Share Anecdotal/Qualitative Information with Others  

For example, EPA may copy a Partner’s “success story” from its
survey form into a word processing program (see Question 3.5 of Initial
Survey).  EPA will review its own work carefully to identify and correct
data entry errors. EPA will evaluate the success story to determine if
the public or others, such as current or prospective partners, would
benefit by reading it.  If so, EPA may share this information with the
public (e.g., on the SC3 web site).

(iii)	To Share Quantitative Information with Others  

EPA may keep track, for example, of the number of schools that have
received support by SC3 Partners.  The survey forms include questions
that enable EPA to keep track of the number of schools supported by a
Partner since it joined the Program (e.g., see Question 1.4 of Initial
Survey).  These questions are designed to avoid the double-counting of
schools and other data quality problems.  EPA may enter the number of
schools from Partners’ surveys into a spreadsheet and add them up to
derive the total number.  EPA may share this total with the public
(e.g., at the SC3 web site).  For example, EPA may use the following
type of statement: “Based on the SC3 Survey, Partners have supported [
 ] schools under SC3 since joining the Program.” 

Note:  EPA will share qualitative and quantitative information with
others only by providing a straightforward presentation of the
information as reported by Partners.  EPA will not manipulate the data
in any way, except to summarize or add up data (e.g., to add up the
total number of schools supported by Partners).  

EPA will not perform any of the following statistical methods with the
information collected: 

Calculations of mean, median, or modal values. 

Regression, extrapolation, imputations (e.g., to address missing data),
or other data modeling.

Establish a cause and effect link between the SC3 Program and Partner
activities and accomplishments.    

 The Initial Survey and Annual Update both include Parts 1-3 as
described below.  

 Although EPA pilot tested only the Initial Survey, Partners’
suggestions and concerns have been addressed in the Annual Update as
well.

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df .  For the 36.45% fringe benefits estimate see the Update to Civilian
Position Full Fringe Benefit Cost Factor, Federal Pay Raise Assumptions,
Inflation Factors, and Tax Rates used in OMB Circular No. A-76,
“Performance of Commercial Activities," October 31, 2006.  The
document can be found at:
http://www.whitehouse.gov/omb/memoranda/fy2007/m07-02.pdf.

 An ICR is normally effective for three years from the date of OMB
approval.  After three years, the ICR must be updated and submitted to
OMB for renewal.

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A- PAGE  1  

B- PAGE   8 

 

