Contact Tracing Emergency ICR_3

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460

OFFICE OF MISSION SUPPORT

MEMORANDUM
SUBJECT:

Emergency Information Collection Request for Public Health Emergency Workplace
Response System (OMB Control Number 2030-NEW; EPA ICR Number 2676.01)

FROM:

Daniel Coogan, Acting Director
Office of Resources and Business Operations

DANIEL
COOGAN

THRU:

Courtney Kerwin, PRA Clearance Officer
and Director for Regulatory Support Division
Office of Enterprise Information Programs

COURTNEY
KERWIN

TO:

Danielle Jones, OMB Desk Officer
Office of Information and Regulatory Affairs
Office of Management and Budget

Digitally signed by DANIEL
COOGAN
Date: 2020.11.30 15:43:20
-05'00'

Digitally signed by COURTNEY
KERWIN
Date: 2020.11.30 18:06:36 -05'00'

Pursuant to section 3507(j) of the Paperwork Reduction Act (PRA) (44 U.S.C. 3501 et seq.), as implemented
in the Office of Management and Budget (OMB) regulations at 5 CFR §1320.13, the Environmental
Protection Agency (EPA) is hereby requesting emergency processing of an information collection
necessary for contact tracing EPA employees, contractors and grantee recipients that perform work in
EPA facilities.

Following the normal clearance procedures for approval of this information collection during the
COVID-19 pandemic response will delay the Agency’s ability implement contract tracing and to
adequately protect its workforce. EPA certifies the requirements of 5 CFR 1320.13(a) are met and it is
vital for this collection to be implemented immediately because: (1) this information is necessary to
protect EPA’s workforce, (2) public harm is reasonably likely to result if normal clearance procedures
are followed, and (3) an unanticipated event has occurred.
Information Collection is Essential to the Mission of the Agency
OMB Memorandum M-20-23, “Aligning Federal Agency Operations with the National Guidelines for
Opening Up American Again,” dated April 20, 2020, requires employers to develop and implement policies
and procedures for workforce contact tracing following an employee’s COVID-19 positive test. In doing so,
M-20-23 requires symptomatic Federal employees and contractors to follow their Agency’s process if they
are symptomatic or test positive for COVID-19. EPA’s processes will protect the anonymity and privacy of
Federal employees and contractors, to the extent possible, while disclosing only the information necessary
for agencies to take appropriate actions of notifying potentially affected employees and cleaning the facility.
Additionally, per the Centers for Disease Control and Prevention (CDC) guidance entitled Get and Keep
America Open, COVID-19 Contact Tracing is essential to reduce the spread of COVID-19. Furthermore, in

response to the Coronavirus Pandemic, public health leaders are calling for communities around the country
to ramp up capacity and implement a massive contact tracing effort to control spread of the Coronavirus. The
response and recovery from the effect of COVID-19 will continue to present Federal agencies with
unprecedented challenges, as well as opportunities for improvement, that require new processes and practices
such as COVID-19 Contact Tracing to keep the workforce and the public safe. As EPA plans to reconstitute
the workforce, it is essential to have an internal EPA Contact Tracing Program that informs mission
readiness and protects our workforce.
Information Collection Activities Involved in this Emergency Request
Because of the substantial risk to life, safety, or health of the workforce and the public, EPA requests
emergency approval to collect the necessary information from detailees, interns, volunteers, grantee
recipients and contractors that perform work in EPA facilities to implement an effective COVID-19 Contact
Tracing program.
Each item of information requested is based on CDC and industry best practice for Contact Tracing. This
information is necessary to identify individuals in the workforce who are COVID-19 positive and to notify
and trace persons in the workforce who were in close contact with the COVID-19 positive employee. This
enables EPA to capture the total workforce and take appropriate action.
The following information will be collected for COVID Contact Testing:
- Name;
- Work location;
- Contact information;
- Supervisor;
- Health status;
- Close contacts (as defined by CDC) when in the office; and
- Building and floors visited during period of possible transmission (as defined by CDC).
EPA Cannot Reasonably Comply with the Normal Clearance Procedures
EPA cannot reasonably comply with the normal clearance procedures because: (1) an unanticipated event has
occurred; and (2) public harm is reasonably likely to result if normal clearance procedures are followed.
As the COVID-19 pandemic continues to grow, the full scope of the impact to Americans remains unknown.
We do know however that for government offices to safely open, a robust contact tracing program must be
implemented. Contract tracing is a critical tool to control the spread of COVID-19. Delay in approval of this
information collection will disrupt EPA’s ability identify, alert, isolate and trace COVID-19 positive
members of the EPA workforce. In order to reconstitute its workforce of federal employees, contractors,
volunteers, grantees, and interns, EPA must be aware of potential office outbreaks, workforce exposures, and
areas requiring sanitization to prevent the further spread of COVID-19. It would be impracticable and
contrary to the public health to delay implementing this collection of information collection until after EPA
has completed the normal PRA clearance procedures.
Agency Has Taken All Practicable Steps to Consult with Affected Parties in Order to Minimize
Burden
To formulate the data elements to be collected for proper and efficient contact tracing, EPA consulted the
CDC, EPA Public Health experts, and the Department of Homeland Security’s Contact Tracing Team.
Requested Time Period for OMB Action

EPA requests that OMB take action on this request by December 4, 2020.

Thank you for your assistance in processing this request. Should any questions arise, please contact me
at 202-564-1862 or Courtney Kerwin at 202-566-1669.

ATTACHMENT 1: Estimated Burden and Costs for This Information Collection Activity
Type of
Respondent
Survey

Form
Name

Public
Health
Emergency
Workplace
Response
System

Number of
Number of Number of
Respondents Responses
Responses
per
(Total)
Respondent
250
1
250

Bottom Line Burden
Respondents:
Responses:
Hours:
Capital/O&M Costs:

250
250
62.5
$0

ATTACHMENT 2: Information Collection Instrument

Average
Burden
per
Response
.25

Total
Annual
Burden
(hours)
62.5