Supporting Statement for Information Collection
Identification of Products with Environmental Attributes
GSAR Clause Affected: 552.238-78
Overview of Information Collection
This is a request for approval of an extension to an existing information collection.
This information collection applies to General Services Administration (GSA) contracts requiring contractors to identify products with environmental attributes. Federal Agencies will utilize this information to determine if such products will meet their needs, and use the information gathered to determine if the product is more advantageous to a competing, non-environmental attributed product.
GSAR Clause 552.238.78 re-enforces elements of the Energy Policy and Conservation Act (42, U.S.C. 6201 et seq.)
Energy Policy Act of 1992 (Public Law 102-486)
Clean Air Act Amendments of 1990 (Public Law 101-549)
Resource Conservation and Recovery Act (42 U.S.C. 6901 et seq.);
The General Services Administration Acquisition Regulation (GSAR) sections covered by this information collection include:
GSAR Clause 552.238-78 Identification of Products That Have Environmental Attributes
The following are changes of importance that have occurred since the last extension approval:
The total estimated respondents per year increased due to the use of updated data. The total estimated respondents changed-
From: 744
To: 943
The total estimated annual public cost burden increased due to the use of updated data. The total estimated annual public cost burden changed-
From: $47,995
To: $60,672
The total estimated annual cost burden to the Government increased due to the use of updated data. The total estimated annual cost to the Government changed-
From:$23,998
To: $30,336
1. Need and Method for the Information Collection.
This justification supports a request for renewal of a currently approved collection under OMB Control Number 3090-0262 for GSA’s GSAR Clause 552.238-78 Identification of Products That Have Environmental Attributes. Federal Agencies will utilize this information to determine if such products will meet their needs, and use the information gathered to determine if the product is more advantageous to a competing, non-environmental attributed product.
The information collected is submitted electronically (to the maximum extent possible).
See Item 6 below for the consequences if the information collection is not conducted or conducted less frequently.
2. Use of the Information.
GSA will utilize the requested disclosure of products with environmental attributes, reported by GSA Federal Supply Schedule contractors, to determine if such products will meet their needs and statutory guidance described above. This information will flow down to GSA’s federal customers who utilize the Federal Supply Schedule to meet their acquisition needs.
3. Use of Information Technology.
The Government uses improved information technology to the maximum extent practicable. Where both the General Services Administration and contractors are capable of electronic interchange, the contractors may submit information requirements electronically. This information is utilized for GSA’s Federal Schedules purposes, to provide the best product options for the Government on the Schedule.
4. Non-duplication.
Similar data requests have been asked for specific programs such as Energy Star or contents of pesticides by the EPA. While similar to what is being asked here, GSA is requesting this information specifically from the Federal Supply Schedule holders in accordance with the terms of their contracts.
5. Burden on Small Business.
The burden applies equally to both small and large organizations that want to do business with GSA. However, it is the minimum necessary to meet the specific objectives of the solicitation or contract.
6. Less Frequent Collection.
Government would not be able to identify products that have environmental attributes and benefits and therefore would not be in compliance with Energy Policy and Conservation Act (42, U.S.C. 6201 et seq.), the Energy Policy Act of 1992 (Public Law 102-486), the Clean Air Act Amendments of 1990 (Public Law 101-549), and the Resource Conservation and Recovery Act (42 U.S.C. 6901 et seq.).
7. Paperwork Reduction Act Guidelines.
Not applicable, no special circumstances exist for this information collection.
8. Consultation and Public Comments.
A 60-day notice published in the Federal Register at 89 FR 52052 on June 21, 2024. No public comments were received. A 30-day notice was published in the Federal Register at 89 FR 68617 on August 27, 2024.
GSA did not pursue consultation outside of the agency other than the notice, because the information requested is specific to the Federal Supply Schedule contracts terms and conditions and is utilized to provide GSA with additional insight as to what is provided to federal customers who utilize the schedules.
9. Gifts or Payment.
Not applicable, GSA makes no such payments or gifts to respondents under this information collection.
10. Privacy and Confidentiality.
Not applicable, GSA makes no additional assurances under this information collection beyond what is already applicable to contract information (i.e., information collected is disclosed only to the extent consistent with prudent business practices, agency regulations, and applicable statutes).
11. Sensitive Questions.
Not applicable, no sensitive questions are involved under this information collection.
12. Burden Estimate.
The total public reporting burden for this collection of information includes the time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information.
The estimated number of respondents annually has increased to 943 with each response requiring 1 hour for a total of 943 hours. The number of annual respondents was determined by identifying the number of current contracts that have at least one product with an environmental attribute that requires a response in accordance with GSAR clause 552.238-78.
Based on estimates of number of contracts; estimated burden hours to the public:
Estimated respondents per year 943
Estimated responses per respondent x 1
Total responses annually 943
Estimated hours per response x 1
Estimated total burden hours 943
The estimated total burden hours was determined by identifying the number of contracts that have at least one product with an environmental attribute that requires a response in accordance with GSAR clause 552.238-78.
Estimated total burden hours 943
Cost per hour* x $64.34
Total annual recordkeeping cost $60,672
*The cost of $64.34 per hour is based on the mean hourly wage for a journeyman at the 2024 GS-12, Step 5 level (Base Pay and Rest of US Locality Pay) (Salary Table 2024-GS, Effective January 2024), with fringe of 36.25% (OMB Memo M-08-13).
|
Requested |
Program Change Due to New Statute |
Program Change Due to Agency Discretion |
Change Due to Adjustment in Agency Estimate |
Change Due to Potential Violation of the PRA |
Previously Approved |
Annual Number of Responses for this IC |
943 |
N/A |
N/A |
199 |
N/A |
744 |
Annual IC Time Burden (Hour) |
943 |
N/A |
N/A |
51 |
N/A |
744 |
Annual IC Cost Burden (Dollars) |
$60,672 |
N/A |
N/A |
$12,677.62 |
N/A |
$47,995 |
Burden per Response:
|
|
||||||||||||||||||||
Annual Burden:
|
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13. Estimated Nonrecurring Costs.
Not applicable to this information collection.
14. Estimated Cost of the Government
The estimated annual cost to the Federal Government is $30,336 (471.5 total burden hours x $64.34*). Each response should take approximately 0.50 hours (30 minutes) to process and review. The annual estimated hours require to review responses is 471.5* (943 * 0.50).
Estimated responses per year 943
Estimated reviewing time per response x 0.50
Estimated total review hours 471.5
Cost per hour* x $ 64.34
Total annual Government costs $30,336
*The cost of $64.33 per hour is based on the mean hourly wage for a journeyman at the 2024 GS-12, Step 5 level (Base Pay and Rest of US Locality Pay) (Salary Table 2024-GS, Effective January 2024), with fringe of 36.25% (OMB Memo M-08-13).
15. Reasons for Changes.
Costs increased due to several factors.
More contractors are providing products with environmental attributes, with the total participants increasing from 744 in 2021 to 943 in 2024.
The hourly rate (plus fringe) was updated to reflect the rates effective January 2024, as opposed to January 2021.
The personnel equivalent was updated from a GS-12 Step 5 salary with the 2024 rate of $64.34 per hour, which reflects ($47.22 per hour plus 36.25% = $64.34)
The average number of documents submitted to GSA’s contracting officer remained the same.
16. Publicizing Results.
Not applicable, results of this information collection will not be published. Information collected is used for internal purposes only.
17. OMB Not to Display Approval.
Not applicable, GSA is not seeking such approval for this collection.
18. Exceptions to “Certification for Paperwork Reduction Submissions”.
Not applicable, GSA has no exceptions to the certification statement.
19. Surveys, Censuses, and Other Collections that Employ Statistical Methods.
Surveys, censuses or statistical methods are not used for this information collection.
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| File Modified | 0000-00-00 |
| File Created | 2024-09-06 |