Attachment K- Consultation

ATTACHMENT K
Stakeholder Consultation
As required under 5 CFR 1320.8(d)(1), EPA staff contacted appropriate stakeholders
and asked them for their assessment of the regulatory burden estimates expressed by
the Agency in this ICR.
EPA asked stakeholders the following questions:
• Are the data that are required to be submitted under this ICR available from any
other public source that you are aware of, or are they data already collected by
another EPA office or by another agency? If so, where can you find the data?
• Based on the instructions, is it clear to the respondents what they may be
required to do and how to submit such data? If not, what suggestions do they
have to clarify the instructions? Are reporting forms clear, logical, and easy to
complete?
• Is the proposed collection of information necessary for the proper performance of
the functions of the Agency, including whether the information will have practical
utility?
• Are the Agency's estimates of the burden of the proposed collection of
information, including the validity of the methodology and assumptions used,
reasonable and accurate?
• Could the quality, utility, and clarity of the information to be collected be
improved?
EPA contacted the following stakeholders, whose responses are included in full in this
attachment:

From:
To:
Cc:
Subject:
Date:
Attachments:

FW: Safer Choice ICR
Friday, July 30, 2021 9:18:15 AM
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Hello and happy Friday,
Another response from the ICR consultation.

www.epa.gov/saferchoice

#EPASaferChoice

Subject: RE: Safer Choice ICR

Sorry to be so late with this reply. I sent out your request to the EPP Task Force. That group is
comprised of many companies who participate in the various Safer Choice programs.
For our part, I’ve been talking with ACI’s comms team who put together the submission for the
Partner of the Year award. They estimate 10 hours for the tracking, pulling, writing, formatting and
review involved in this year’s submission.

Hope this helps!

Subject: FW: Safer Choice ICR
[EXTERNAL SENDER]

Here’s the Safer Choice ICR.
Thanks,

#EPASaferChoice

From:
To:
Cc:
Subject:
Date:
Attachments:

FW: Help with the Safer Choice ICR
Tuesday, July 27, 2021 6:25:15 AM
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Here is the response from ISSA on the ICR consultation.

www.epa.gov/saferchoice

#EPASaferChoice

Sent: Thursday, July 22, 2021 2:33 PM
Subject: RE: Help with the Safer Choice ICR

Thank you very much for inviting ISSA to comment on the questions posed below related to the
Safer Choice ICR. Our answers to the questions presented in your email are set forth below in the
order asked.

I. Are the data that are required to be submitted under this ICR available from any
other public source that you are aware of, or are they data already collected by
another EPA office or by another agency? If so, where can you find the data?

ISSA RESPONSE:  In the opinion of ISSA, the data required to be submitted under
the ICR is not available from any other public source that ISSA is aware of. 
Moreover, we believe that the required data is not something that is already
collected by another office within EPA or any other agency that we are aware of.
II. Based on the instructions, is it clear to the respondents what they may be
required to do and how to submit such data? If not, what suggestions do they
have to clarify the instructions?  Are reporting forms clear, logical, and easy to
complete?
ISSA RESPONSE:  Yes, we believe the instructions are clear in describing to
respondents what they are required to do including the submission of data.  ISSA
believes the reporting forms are clear, logical and easy to complete.
III. Is the proposed collection of information necessary for the proper performance of
the functions of the Agency, including whether the information will have practical
utility?
ISSA RESPONSE:  Yes, in the opinion of ISSA, the proposed collection of
information is necessary for the proper performance of the functions of EPA. 
More specifically, the information solicited will be of great utility to EPA going
forward and assist the Agency in its functions.
IV. Are the Agency's estimates of the burden of the proposed collection of
information, including the validity of the methodology and assumptions used,
reasonable and accurate?
ISSA RESPONSE:  In ISSA’s opinion, the EPA’s estimates of the burden of the
proposed collection of information is reasonable and accurate given the task at
hand.  Furthermore, we believe the methodology and assumptions to be both
valid and appropriate. 
V. Could the quality, utility, and clarity of the information to be collected be
improved?
ISSA RESPONSE:  No.  We do not believe that the quality, utility or clarity of
the information to be collected could be improved significantly. 
Linda, we sincerely hope that the above responses adequately address the questions posed. Should
you have any questions, please feel free to contact me directly.

ISSA

On June 28, 2021, the U.S. Environmental Protection Agency (EPA) published a notice in the
Federal Register (FR 10023-20) announcing that EPA is planning to submit a request to
renew and consolidate existing approved Information Collection Requests (ICRs) to the
Office of Management and Budget (OMB), and requesting public comment.  The
consolidated ICR is entitled: “Safer Choice Program Product and Partner Recognition
Activities” identified by EPA ICR No. 2691.01 and OMB Control No. 2070-[new].  This ICR will
cover the information collection activities associated with the reporting and recordkeeping
requirements for individuals, businesses, organizations, and government entities
participating in or collaborating with EPA’s Safer Choice program.  These components are
designed to: Improve data efficiency by electronic data collection via a cloud-based
Salesforce system called the Safer Choice Community; Monitor the public’s awareness of the
Safer Choice program and label; and, Clarify the Safer Choice Partner of the Year Awards
application process and form. 
Before submitting the consolidated ICR to OMB for review and approval, EPA is soliciting
comments on specific aspects of the proposed information collection.  Please note that if
you take this opportunity to provide input, your name, affiliation, e‐mail address, phone
number and any information you provide (e.g., copies of e‐mails) will be incorporated and
attached to the ICR supporting statement, which will be a public document. 
As a potential respondent, we would value your feedback on the following questions:
I. Are the data that are required to be submitted under this ICR available from any
other public source that you are aware of, or are they data already collected by
another EPA office or by another agency? If so, where can you find the data?
II. Based on the instructions, is it clear to the respondents what they may be
required to do and how to submit such data? If not, what suggestions do they
have to clarify the instructions?  Are reporting forms clear, logical, and easy to
complete?
III. Is the proposed collection of information necessary for the proper performance of
the functions of the Agency, including whether the information will have practical
utility?
IV. Are the Agency's estimates of the burden of the proposed collection of

information, including the validity of the methodology and assumptions used,
reasonable and accurate?
V. Could the quality, utility, and clarity of the information to be collected be
improved?
We will send a copy of the ICR tomorrow. For your reference, here is a link to the federal
register notice: https://www.federalregister.gov/documents/2021/06/28/202113683/agency-information-collection-activities-proposed-renewal-and-consolidation-ofcurrently-approved.
If you have any comments in response to the above questions, or with respect to any other
part of this ICR, please respond by return e-mail by August 2, 2021 to [email protected].
EPA will consider those responses, as well as any public comment received in response to
the Federal Register notice identified above, in preparing a final document for OMB review.
Thanks in advance for your time and assistance!
Kind regards,

#EPASaferChoice

Subject: Help with the Safer Choice ICR

I have a favor to ask. I hope it isn’t a large burden. We are writing to request your feedback on
materials that describe how much time companies spend working with our program in terms of
information collection activities.
The Paperwork Reduction Act (PRA) requires us to issue an Information Collection Request (ICR)
through a public notice and comment process. On Monday, June 28th, we published and solicited
comment through a Federal Register Notice explaining our work to renew and consolidate Safer
Choice ICRs under the PRA. We are consolidating three ICRs for Safer Choice: product review and
approval; consumer awareness survey; and Partner of the Year. The PRA also requires that we
conduct consultations representing the views of those who work with the program. You have helped
us with the ICR consultation process in the past, and we are hoping we can lean on you again.
The timing estimates in the draft ICR are based in large part on our experience working with our
partners, our third parties, and our data system. Some estimates may be updated from the last
time that you saw them, but adjustments are marginal. Please note that these estimates are for
partnering in existing product categories – not for opening new categories.
Your responses could be quite brief if you continue to agree that our estimates reflect a reasonable
estimate of the time partners take in working with our program.
In a few moments, will send a more detailed ask with links and questions. We would appreciate your
feedback by August 2.

For visitors to EPA: epa.gov/aboutepa/hq.html
For information on Safer Choice: epa.gov/saferchoice

#EPASaferChoice

Subject: Help with the Safer Choice ICR
I have a favor to ask. I hope it isn’t a large burden. We are writing to request your feedback on
materials that describe how much time companies spend working with our program in terms of
information collection activities.
The Paperwork Reduction Act (PRA) requires us to issue an Information Collection Request (ICR)
through a public notice and comment process. On Monday, June 28th, we published and solicited
comment through a Federal Register Notice explaining our work to renew and consolidate Safer
Choice ICRs under the PRA. We are consolidating three ICRs for Safer Choice: product review and
approval; consumer awareness survey; and Partner of the Year. The PRA also requires that we
conduct consultations representing the views of those who work with the program. You have helped
us with the ICR consultation process in the past, and we are hoping we can lean on you again.
The timing estimates in the draft ICR are based in large part on our experience working with our
partners, our third parties, and our data system. Some estimates may be updated from the last
time that you saw them, but adjustments are marginal. Please note that these estimates are for
partnering in existing product categories – not for opening new categories.
Your responses could be quite brief if you continue to agree that our estimates reflect a reasonable
estimate of the time partners take in working with our program.

In a few moments, will send a more detailed ask with links and questions. We would appreciate
your feedback by August 2.

Comments received from the Household & Commercial Products Association
(HCPA)

From:
To:
Cc:
Subject:
Date:
Attachments:

FW: Help with the Safer Choice ICR
Monday, August 30, 2021 8:09:55 PM
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ATT00001.txt
HCPA Safer Choice ICR Comments.pdf

Warning from Abt: External email. Be careful opening links and attachments.

#EPASaferChoice

Subject: Re: Help with the Safer Choice ICR

I submitted the attached comments on the ICR last week (hopefully they came through the
docket – I have a confirmation, if they did not) – which reflect that the cost estimates in the ICR are
consistent with our experiences, primarily the PotY portion.
Thanks

Subject: FW: Help with the Safer Choice ICR
HI,
Thanks for calling the other day.
If I understand correctly, you don’t have comments on the ICR and the estimates seem generally in
line with real-world values.
If I understand this correctly, could you please reply to me and Linda and let us know that that is the
case?
Thanks so much. It would be really helpful to us.

Subject: RE: Help with the Safer Choice ICR
Dear ,

On June 28, 2021, the U.S. Environmental Protection Agency (EPA) published a notice in the
Federal Register (FR 10023-20) announcing that EPA is planning to submit a request to
renew and consolidate existing approved Information Collection Requests (ICRs) to the
Office of Management and Budget (OMB), and requesting public comment.  The
consolidated ICR is entitled: “Safer Choice Program Product and Partner Recognition
Activities” identified by EPA ICR No. 2691.01 and OMB Control No. 2070-[new].  This ICR will
cover the information collection activities associated with the reporting and recordkeeping
requirements for individuals, businesses, organizations, and government entities
participating in or collaborating with EPA’s Safer Choice program.  These components are
designed to: Improve data efficiency by electronic data collection via a cloud-based
Salesforce system called the Safer Choice Community; Monitor the public’s awareness of the
Safer Choice program and label; and, Clarify the Safer Choice Partner of the Year Awards
application process and form. 
Before submitting the consolidated ICR to OMB for review and approval, EPA is soliciting
comments on specific aspects of the proposed information collection.  Please note that if
you take this opportunity to provide input, your name, affiliation, e‐mail address, phone
number and any information you provide (e.g., copies of e‐mails) will be incorporated and
attached to the ICR supporting statement, which will be a public document. 
As a potential respondent, we would value your feedback on the following questions:
I. Are the data that are required to be submitted under this ICR available from any
other public source that you are aware of, or are they data already collected by
another EPA office or by another agency? If so, where can you find the data?
II. Based on the instructions, is it clear to the respondents what they may be
required to do and how to submit such data? If not, what suggestions do they
have to clarify the instructions?  Are reporting forms clear, logical, and easy to
complete?
III. Is the proposed collection of information necessary for the proper performance of
the functions of the Agency, including whether the information will have practical
utility?
IV. Are the Agency's estimates of the burden of the proposed collection of
information, including the validity of the methodology and assumptions used,
reasonable and accurate?
V. Could the quality, utility, and clarity of the information to be collected be
improved?

We will send a copy of the ICR tomorrow. For your reference, here is a link to the federal
register notice: https://www.federalregister.gov/documents/2021/06/28/202113683/agency-information-collection-activities-proposed-renewal-and-consolidation-ofcurrently-approved.
If you have any comments in response to the above questions, or with respect to any other
part of this ICR, please respond by return e-mail by August 2, 2021 to [email protected].
EPA will consider those responses, as well as any public comment received in response to
the Federal Register notice identified above, in preparing a final document for OMB review.
Thanks in advance for your time and assistance!

#EPASaferChoice

Subject: Help with the Safer Choice ICR
Dear
I have a favor to ask. I hope it isn’t a large burden. We are writing to request your feedback on
materials that describe how much time companies spend working with our program in terms of
information collection activities.

The Paperwork Reduction Act (PRA) requires us to issue an Information Collection Request (ICR)
through a public notice and comment process. On Monday, June 28th, we published and solicited
comment through a Federal Register Notice explaining our work to renew and consolidate Safer
Choice ICRs under the PRA. We are consolidating three ICRs for Safer Choice: product review and
approval; consumer awareness survey; and Partner of the Year. The PRA also requires that we
conduct consultations representing the views of those who work with the program. You have helped
us with the ICR consultation process in the past, and we are hoping we can lean on you again.
The timing estimates in the draft ICR are based in large part on our experience working with our
partners, our third parties, and our data system. Some estimates may be updated from the last
time that you saw them, but adjustments are marginal. Please note that these estimates are for
partnering in existing product categories – not for opening new categories.
Your responses could be quite brief if you continue to agree that our estimates reflect a reasonable
estimate of the time partners take in working with our program.
In a few moments, will send a more detailed ask with links and questions. We would appreciate
your feedback by August 2.
Thanks very much,

August 27, 2021
Data Gathering and Analysis Division, 7406M
Office of Pollution Prevention and Toxics
Environmental Protection Agency
1200 Pennsylvania Ave. NW, Washington, DC 20460–0001
Re: Agency Information Collection Activities; Proposed Renewal and Consolidation of
Currently Approved Collections; EPA’s Safer Choice Program Product and Partner
Recognition Activities (EPA–HQ–OPPT–2021–0245)

On behalf of the Household & Commercial Products Association1 (HCPA) and its
members, we are submitting comments on the Agency Information Collection
Activities; Proposed Renewal and Consolidation of Currently Approved Collections;
EPA’s Safer Choice Program Product and Partner Recognition Activities (EPA–HQ–
OPPT–2021–0245). HCPA has a long history of supporting the Safer Choice program
and many of our member companies are active partners as well.
As a multi-time submitter of a Safer Choice Partner of the Year award (and a proud
recipient) we are pleased to note that the estimates of burden are reflective of our
experience. One area that does not appear to be accounted for is associated with the
Safer Choice Partner of the Year award ceremony itself. While the ceremony itself is
outside of the scope of this collection effort, it is not clear that the information that is
collected in advance of the award ceremony is adequately accounted for in this request.
This would include information such verifying the awardee information, logos of the
awardee of the award, and other materials associated with the award ceremony.
While HCPA itself has had minimal experience with product submissions, we have
performed a pilot product submission and the estimates are consistent with our
experience. We will note that there can be considerable variability at the product
review stage by the third-party certifiers that can vary greatly depending upon whether
ingredients are listed on the Safer Choice Ingredient List (SCIL), have been previously
evaluated, or are new ingredients undergoing evaluation. We have encouraged our
members to share their experiences to the extent possible to better provide the agency a
1

HCPA represents products including disinfectants that kill germs in homes, hospitals and
restaurants; air fresheners, room deodorizers, and candles that eliminate odors; pest management
products for pets, home, lawn, and garden; cleaning products and polishes for use throughout the home
and institutions; products used to protect and improve the performance and appearance of automobiles;
aerosol products and a host of other products used every day.

better appreciation for the associated burden.
We thank you for this opportunity to share our input and look forward to working
with EPA and the Safer Choice program.

Sincerely,

Executive Vice President, Scientific & Regulatory Affairs
Household & Commercial Products Association

2