October 31, 2013
Supporting Statement for a Request for OMB Review
under the Paperwork Reduction Act
EPA’s Design for the Environment (DfE) Logo Redesign Consultations
ICR Numbers: EPA ICR No. 2487.01 OMB Control No. 2070-NEW
This new information collection request (ICR) is to address the consultation process that would assist the U.S. Environmental Protection Agency (EPA) with the selection of a revised logo and messaging for its Design for the Environment (DfE) Program. A key goal of the Office of Pollution Prevention and Toxics (OPPT)’s DfE Program is to work with businesses to voluntarily incorporate safer chemicals and other health and environmental considerations into the design of their products and processes. To achieve this goal, EPA relies on outreach activities and information dissemination to industry participants and the public, as well as non-governmental organizations, other federal agencies, and state and local governments.
Through its DfE Safer Product Labeling Program, EPA has recognized more than 2,500 products that meet the Agency’s stringent human health and environmental criteria. Effective outreach and communications to businesses and the public are vital to the program’s success.
DfE’s logo has remained unchanged since the program began in 1992 and, according to stakeholder feedback, as described in A.3.c., does not fully and effectively represent DfE’s mission to advance chemical-based products that are safer for people and the environment. A redesigned logo and messaging are needed to enhance communications and for the program to reach its potential. It is important for the DfE redesign effort to be informed by consumers, manufacturing partners, retailers, and other key audiences.
DfE’s logo redesign and accompanying communication and outreach efforts could:
better convey the program’s scientific expertise and the human health and environmental benefits of using safer products,
increase consumer recognition of safer products carrying the redesigned DfE logo,
encourage businesses to participate in the DfE Program, and
This ICR would enable DfE to conduct consumer focus groups; a consumer online survey to test selected redesigned logo concepts and messaging for clarity, relevance, and appeal. The focus groups will pre-date the surveys and will serve to gather feedback about logo designs before they are refined for final testing through the pre-launch survey. Post-launch consumer online surveys will be used to gauge consumer recognition of the new logo, as well as understand how the new logo (and associated outreach) is diffusing over time and whether it is changing purchasing decisions.
Authority for the DfE Program derives from section 6604(b)(5) of the Pollution Prevention Act (PPA), 42 U.S.C. 13103(b)(5) (Attachment A), which directs EPA to facilitate the adoption of source-reduction techniques by businesses, and the Toxic Substances Control Act (15 U.S.C. 2601 et seq.), which encourages safety in technological innovation in chemistry. In recognition of this statutory directive, and through consultation with a broad range of stakeholders, EPA developed the DfE Program.
Testing of DfE’s logo by consumer focus groups and consumer online surveys will help ensure that the logo effectively communicates the Agency’s missions under the PPA and TSCA. A logo that is clear and signals a focus on human health and the environment will increase demand for and encourage the development of safer chemical-based products, to the benefit of consumers, manufacturing partners, retailers, other stakeholders, and the environment.
DfE has carefully tailored this ICR to ensure that it only asks for information essential to testing the qualities of the selected redesigned logo concepts.
The information to be collected by the DfE Program is not designed or intended to support regulatory decision-making by EPA. EPA will use the information collected in these consultations to design or verify that a new logo: (1) better conveys the program’s scientific expertise and the human health and environmental benefits of using safer products, as shown in consumer focus groups and survey testing (2) increases consumer recognition of safer products carrying the redesigned DfE logo, as shown in consumer focus groups and survey testing, and (3) encourages businesses to participate in the DfE Program, given a positive response to the new logo among consumers.
Respondents will not be asked to provide information that has been or is currently being collected by EPA, other federal or state agencies, or proprietary sources. The information collected by the DfE Program is unique and is not duplicative of previous information collection requests
In proposing to renew this ICR, EPA provided a 60-day public notice and comment period that ended on September 23, 2013 (78 FR 44560, July 24, 2013). EPA received two comments during the 60-day public notice and comment period, which are characterized below.
In general the comments addressed the necessity of the proposed ICR and logo redesign. One commenter expressed support for the ICR and the value of public feedback, as well as for redesigning the logo. The commenter said that the logo redesign will “enable the [DfE] program to communicate its human and environmental health protection mission with more clarity and conviction.” These comments are consistent with EPA’s assessment of the need for information collection and a redesigned logo, described in Section A.2.a.
Another commenter stated that the ICR and the redesigned logo were not necessary and not a good use of taxpayer money. As stated in Section A.2.a, there are expected benefits of this ICR for consumers, businesses, and the environment through the design of safer chemical-based products resulting from the use of an effective logo.
The comments in their entirety and EPA’s response to these comments are included in Attachment G.
The Agency has received input from its diverse group of DfE stakeholders regarding its logo redesign. These stakeholders include chemical manufacturers, product manufacturers, non-governmental organizations, government agencies, academics, and retailers. On May 21, 2013, DfE hosted a webinar with stakeholders to discuss the logo redesign process. DfE stakeholders pointed out that the current DfE logo does not incorporate the concept of protecting human health, a key component of the Agency’s, and DfE’s, mission. These consultations have informed the questions included in the focus group screening questionnaires (Attachments B and C), the focus group moderator guide (Attachment D), the pre-launch consumer online survey to test logo design options (Attachment E), and the post-launch consumer online survey to gauge consumer recognition of the new logo (Attachment F). The same moderator guide will be used for each focus group.
The focus group respondents and consumer online survey respondents will be members of the general population, so there are no established, organized entities with whom EPA has a purposeful relationship. Since EPA was not able to readily identify potential respondents, consultations with the general public have not been conducted. However, EPA personnel, with the assistance of a contractor with experience in conducting consumer market research, will design the materials for the screening questionnaires, focus groups, and consumer online surveys. The overall conclusions (descriptive and summary statistics) of the focus groups and online survey will be publicly available; however, all information will be aggregated, with no identification of individuals. Participants will be informed in advance that there will be an aggregated report of conclusions available to the public following the completion of the research. Participants will be reassured that no individually identifiable information will be included in the report.
Up to 10 consumer focus groups will be convened to test selected DfE logo design concepts. Of the consumer focus groups, half will be conducted with general adult consumers and half will be conducted with consumers who consider the environment when making purchasing decisions (i.e., “leaning green” consumers). Additional details about recruitment for and implementation of the focus groups are provided in Statement B (section B.6 “Approach To Conducting Consumer Focus Groups”). Each consumer focus group consultation is designed to be a one-time information collection activity with consumers specifically recruited for the DfE logo redesign. The pre-launch consumer online survey to test logo design options will be a one-time information collection activity. The three post-launch consumer online surveys will be conducted to gauge recognition of the new logo. Each post-launch consumer online survey will be one-time information collection activity. This means that once these activities end, no additional information collection activities will be required. Without these information collection mechanisms, DfE will not have the ability to test and verify consumer perceptions and understanding of the new design and if products displaying the new logo might affect the likelihood of acceptance and use.
The information collection activities discussed in this ICR comply with all regulatory guidelines under 5 CFR 1320.5(d)(2). The collection is tailored to the Agency’s purposes under the Pollution Prevention Act to maximize the integrity and utility of the information while imposing the least burden on potential respondents. In addition, EPA has detailed the statistical methods that will be applied to the collection activities in Part B of EPA’s supporting statement.
EPA does not expect that any information collected under this ICR will involve confidential business or trade secret information given that the data collection instruments are oriented to consumers. The information collected will only pertain to the opinions of the respondents on the specific characteristics of the selected logo concepts as to their clarity, relevance, appeal, and likelihood of using products that display the new design. The DfE Program will use information provided by consumers solely for purposes related to determining the most appropriate redesigned logo. In the report of the research, all information will be aggregated, with no identification of individuals. Participants will be informed in advance that there will be an aggregated report of conclusions available to the public following the completion of the research. Participants will be reassured that no individually identifiable information will be included in the report.
The information collection activities discussed in this document do not involve any sensitive questions involving sexuality, religious beliefs, political affiliation, or other matters considered private, as referred to in theSupporting Statement for PRA Submissions in the document “Guidance on Agency Survey and Statistical Information Collections,” from January 20, 2006. EPA will adhere to its Privacy Policy (EPA classification number 2151) that establishes requirements for safeguarding the collection, access, use, dissemination, and storage of personally identifiable information (PII) and Privacy Act information in accordance with the Privacy Act of 1974, the E-Government Act of 2002, the Federal Information Security Management Act (FISMA), and policy and guidance issued by the President and Office of Management and Budget (OMB).
.
Respondents will be adult members of the general population who are consumers, including consumers who consider the environment when making purchasing decisions (i.e., “leaning green” consumers).
Respondents screened for focus group participation will:
Listen to questions, and
Provide answers to questions.
Focus groups participants will:
Listen to directions,
Be presented with materials for discussion,
Participate in group discussions, and
Complete forms.
Consumer online survey participants will:
Read directions,
Answer questions, and
Submit online survey.
EPA and its contractor will:
Prepare and review focus group materials,
Prepare and review screener questionnaires,
Conduct focus group screening calls,
Conduct focus groups,
Review and analyze focus group results,
Prepare and review pre-launch and post-launch consumer online surveys,
Conduct consumer online surveys,
Review and analyze consumer online survey results,
Use focus group and pre-launch consumer online survey information to inform DfE consumer logo redesign, and
Use post-launch consumer online survey information to evaluate consumer recognition of redesigned logo.
In collecting and analyzing the information associated with this ICR, EPA and its contractor will use a telephone system and personal computers. The contractor will employ transcription to collect information from focus group participants. The transcriptions will be kept on file but will not be distributed publicly. Personal computers will be used for the consumer online surveys. Detailed information on survey resources is outlined in Part B of this Supporting Statement.
The intended respondents to the information collection activities addressed in this ICR are individual consumers. Individual consumer not small entities, as defined under the Regulatory Flexibility Act. No information will be collected from small entities during this information collection.
Screening calls and focus groups will be scheduled after this ICR is approved. The consumer online survey to test logo design options will be distributed after the completion of the consumer focus groups. Up to three consumer online surveys to gauge recognition of the new logo will be distributed after the redesigned logo has been launched to the public by EPA, and then two additional times during the course of the three-year approval period.
A proposed timetable is outlined as follows:
Activity |
Time Frame |
Secure facilities for focus group sessions |
Two weeks after ICR approval |
Screen individuals for focus group sessions |
Four weeks after ICR approval |
Conduct focus group sessions |
Six to eight weeks after ICR approval |
Develop report of focus groups (with aggregated, de-identified information only) |
Ten weeks after ICR approval |
Adjust logo designs based on feedback from focus groups, in anticipation of testing via survey |
11 weeks after ICR approval |
Program and launch survey to test “near final” logo designs |
13 weeks after ICR approval |
Field survey among participants |
14-15 weeks after ICR approval |
Analyze survey data and draft report with recommendations for final design |
16 weeks after ICR approval |
Field survey to test consumer recognition and perceptions of new design |
Fall 2015 |
Field survey to test consumer recognition and perception of new design |
Spring 2016 |
Field survey to test consumer recognition and perception of new design |
By end of 2016 |
Table 1 presents the estimated respondent burden hours and costs associated with the information collection activities under this ICR. EPA based its burden estimates on its focus groups and online surveys conducted for similar programs.
The average respondent burden is estimated to be 10 minutes or 0.17 hours for respondents screened for the focus groups. This estimate is based on the length of time needed to complete a screening questionnaire. There will be two sets of screening questions used for this information collection, one for general adult consumers and one for adult consumers that lean towards the purchase and use of green products. For each focus group, 90 people will be screened using the respective questionnaire. A total of 900 people will be screened as part of this information collection. There is an estimated total respondent burden of 150 hours for the ten focus group screenings.
The average respondent burden is estimated to be 2 hours for focus group participants. This estimate is based on the length of time designated for each focus group session. There will be ten focus groups conducted during this information collection, five for general adult consumers and five for adult consumers that lean towards the purchase and use of green products. Each focus group will have between 8 to 10 participants. We expect a no-show rate of no more than 2 participants per focus group. For the purpose of calculating burden, we assume that each focus group will have 9 participants. A total of 90 people will participate in the focus groups conducted as part of this information collection. For the ten focus groups, there is an estimated total respondent burden of 180 hours.
The average respondent burden is estimated to be 20 minutes or 0.33 hours for the pre-launch consumer online survey to test logo design options. This estimate is based on the length of time needed to complete the pre-launch consumer online survey. There will be one pre-launch survey administered as part of this information collection. The same survey will be administered to all respondents. A total of 2,000 people will complete the survey as part of this information collection. For the pre-launch consumer online survey, there is an estimated total respondent burden of 667 hours.
The average respondent burden is estimated to be 10 minutes or 0.17 hours for the post-launch consumer online survey to gauge consumer recognition of the new logo. This estimate is based on the length of time needed to complete the post-launch consumer online survey. The will be three iterations of the post-launch consumer online survey conducted during this information collection, each of which will use the same set of questions. The same survey will be administered to all respondents. Each post-launch consumer online survey will have 2,000 respondents. A total of 6,000 people will complete the post-launch consumer online survey as part of this information collection. For the three post-launch consumer online surveys, there is an estimated total respondent burden of 1,000 hours.
To value the respondents’ time, data released on June 12, 2013 from the Bureau of Labor Statistics (BLS) Employer Costs for Employee Compensation – March 20131 was used. The average wage for a civilian worker, which includes private industry and state and local government workers, averaged $21.50 per hour worked in March 2013; benefits for a civilian worker averaged $9.59. The average loaded wage for a civilian worker, and therefore the estimate of the cost of a participant’s time, is $31.09 per hour. No capital or operating and maintenance costs are incurred by respondents under this ICR.
Providing monetary incentives is a standard market research practice (usually a cash or check payment at the close of their research session) for ensuring an acceptable level of participation. An incentive may significantly improve validity and reliability to the extent beyond what is possible through other means. For example, an incentive will help in the recruitment of participants with diverse views and levels of interest in the topic area. EPA is particularly interested in a balanced group of consumers and believes that providing an incentive will improve the quality of the effort. The total incentive/travel reimbursement offered to each focus group participant will be $75 for 2 hours, which includes time for participating in the focus group and travel to and from the focus groups. It is important to note that most of the research on incentives has been based on vehicles other than focus groups, typically large-scale household surveys conducted by mail, internet or interview. Focus groups involve a much higher respondent burden, largely attributable to the time, expense and inconvenience of getting to and from and being at the focus-group site. Given the very real barriers to participation, the incentive must be sufficient to overcome them and increased compensation is a proven means to that end,
Survey participants receive an incentive for participating in the panel. They receive points for completion of the survey, and the points can be redeemed for cash or prizes. Offering points for taking online surveys is standard practice that Ipsos, the survey vendor for this research, follows. Ipsos stipulates this practice in its agreement with survey participants, and therefore, participants expect points as a condition for taking a survey. Not offering the points would negatively impact response rates and would likely violate the terms of Ipsos’ agreement with participants.
Table 1. Estimated Burden and Costs to Respondents
Collection Activity |
Number of Respondents |
Response per respondent |
Hours Per Response |
Total Burden Hours4 |
Total Burden ($) |
Screening for Consumer Focus Groups |
900 |
1 |
0.171 |
150 |
$4,663.50 |
Consumer Focus Group Interviews |
90 |
1 |
22 |
180 |
$5,596.20 |
Pre-Launch Consumer Online Survey |
2000 |
1 |
0.333 |
667 |
$20,726.67 |
Post-Launch Consumer Online Survey |
6000 |
1 |
0.171 |
1000 |
$31,090.00 |
Total |
8,990 |
-- |
-- |
1,997 |
$62,076.37 |
1 The estimated time per response for screening consumer focus groups and the post-launch consumer survey is 10 minutes. Therefore, the hours per response value of 0.17 hours is a rounded value. 2 The time burden for consumer focus groups includes 1.5 hours for the focus group sessions and .5 hours for travel. 3The estimated time per response for the pre-launch consumer survey is 20 minutes. Therefore, the hours per response value of 0.33 hours is a rounded value. 4 The total burden hours are rounded values based on the product of the number of respondents, response per respondent, and hours per response. 5
No capital or operating and maintenance costs are incurred by
respondents under this ICR. |
|||||
Table 2 presents the estimated Agency burden hours and costs associated with the information collection activities under this ICR. EPA based its burden estimates on its focus groups conducted for similar programs2.
The cost to prepare, organize and conduct the ten focus groups is $33,500. This fixed amount includes facility rental, recruiting costs, and transcription. This fixed amount also includes the $75 incentive paid to each of the focus group participants. Although the contractor will make the focus group screening calls, prepare the focus group materials, and conduct the focus groups, Agency staff will need to review the focus group materials, the screener questionnaires, and the focus group results. EPA expects that review of the focus group materials will take about 2.5 hours (0.5 managerial, 2 technical). Reviewing the focus group screening questionnaires will take about 2.5 hours (0.5 managerial, 2 technical). Reviewing the focus group results will take about 25 hours (5 managerial, 20 technical).
The cost to prepare and conduct the four consumer online surveys is $31,500. This fixed cost includes the $12,000 cost to prepare and conduct the pre-launch consumer online survey and the $19,500 cost to prepare and conduct the three post-launch consumer online surveys. This fixed amount includes questionnaire development, programming, online fielding, results reporting, and the rewards points that consumers receive upon completing the survey. Although the contractor will prepare and conduct the consumer online surveys, Agency staff will need to review the survey content, design, and results. EPA expects that review of the survey content and design will take about 5 hours (1 managerial, 4 technical). Reviewing survey results will take about 10 hours (2 managerial, 8 technical).
Agency labor costs are calculated based on hourly basic rates for federal employees in the Washington-Baltimore area published by the Office of Personnel Management effective January 20133. The average hourly labor rate for managerial staff is estimated as the rate for a GS-13 Step 5 employee and the average hourly labor rate for technical staff is estimated as the rate for a GS-10 Step 10 employee. These GS-level assumptions are consistent with those used in past EPA OPPT ICRs. The hourly rates were multiplied by an assumed loading factor of 1.6 to reflect Federal fringe benefits and overhead. This loading factor is from an EPA guide, Instructions for Preparing Information Collection Requests (ICRs) (OPPE, 1992, page 30, footnote 9).
The resulting average hourly labor rates, rounded to the nearest dollar amount, are $77 for managerial staff and $57 for technical staff. The Agency expects most activities related to this ICR to be performed by managerial staff (20 percent) and technical staff (80 percent).
Table 2. Estimated Burden and Costs to Agency
Collection Activity |
EPA Burden Hours |
EPA Costs |
|||
Mgr. |
Technical |
Total EPA Hours |
Contractor Cost |
EPA Cost |
|
Consumer Focus Groups |
|||||
Prepare focus group materials |
0.5 |
2 |
2.5 |
$33,500 for ten focus groups (includes payment to participants) |
$152.50 |
Prepare screener questionnaires |
0.5 |
2 |
2.5 |
$152.50 |
|
Organize and conduct focus groups |
-- |
-- |
0 |
$0.00 |
|
Review focus group results |
5 |
20 |
25 |
$1,525.00 |
|
Subtotal |
6 |
24 |
30 |
$33,500 |
$1,830.00 |
Consumer Online Surveys |
|||||
Prepare consumer online surveys |
1 |
4 |
5 |
$31,500 for four consumer online surveys |
$305.00 |
Review consumer online survey results |
2 |
8 |
10 |
$610.00 |
|
Subtotal |
3 |
12 |
15 |
$31,500 |
$915.00 |
Total |
9 |
36 |
45 |
$65,000 |
$2,745.00 |
1 Contractor cost includes facility rental, recruiting, incentives and rewards points, and transcription. 2
No capital or operating and maintenance costs are incurred by the
Agency under this ICR. |
|||||
a. Respondent Tally
Table 3 below summarizes the total annual estimated respondent burden and cost. These estimates represent the average burden in any given year over the three years covered by this ICR. However, the ten focus groups, their respective screening calls, the pre-launch consumer online survey, and the three post-launch consumer online surveys will only be conducted once over the three-year period.
Table 3. Total Annual Estimated Respondent Burden and Cost Summary
Total # of Respondents |
Average Burden Hours |
Annual Cost |
8,990 |
1,997 |
$62,076.37 |
b. Agency Tally
Table 4 below summarizes the total annual estimated Agency burden and cost (including contractor cost). These estimates represent the average burden in any given year over the three years covered by this ICR. However, the ten focus groups, their respective screening calls, and the consumer online surveys will only be conducted once over the three-year period.
Table 4. Total Annual Estimated Agency Burden and Cost Summary
Burden Hours |
Annual Cost |
45 |
$67,745 |
Since this is a new ICR, change in burden is not applicable.
The annual public burden for this collection of information is estimated to be 0.17 hours per response for screened respondents, 2 hours for respondents that participate in the focus groups, 0.33 hours per response for pre-launch consumer online survey respondents, and 0.17 hours per response for post-launch online survey respondents. Burden is defined in 5 CFR 1320.3(b). 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 number for this information collection appears above. The OMB control numbers for EPA’s regulations in title 40 of the CFR, after appearing in the Federal Register, are listed in 40 CFR part 9 and included on the related collection instrument or form, if applicable.
The Agency has established a public docket for this ICR under Docket ID No. EPA-HQ-OPPT-2013-0403, which is available for online viewing at www.regulations.gov, or in-person viewing at the Pollution Prevention and Toxics Docket in the EPA Docket Center (EPA/DC). The EPA/DC Public Reading Room is located in the EPA West Building, Room 3334, 1301 Constitution Ave., N.W., Washington, DC. The EPA/DC 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 EPA/DC Public Reading Room is (202) 566-1744, and the telephone number for the Pollution Prevention and Toxics Docket is (202) 566-0280.
You may submit comments regarding 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. Submit your comments, referencing Docket ID No. EPA-HQ- OPPT-2013-0403 and OMB Control No. 2070-NEW, to (1) EPA online using www.regulations.gov (our preferred method), or by mail to: Pollution Prevention and Toxics Docket, Environmental Protection Agency Docket Center (EPA/DC), Mailcode: 28221T, 1200 Pennsylvania Ave., N.W., Washington, DC 20460, and (2) OMB by mail to: Office of Information and Regulatory Affairs, Office of Management and Budget (OMB), Attention: Desk Officer for EPA, 725 17th Street, N.W., Washington, DC 20503.
ATTACHMENTS TO THE SUPPORTING STATEMENT
Attachments to the supporting statement are available in the public docket established for this ICR under docket identification number EPA–HQ–OPPT-2013-0403. These attachments are available for online viewing at www.regulations.gov or otherwise accessed as described in section 6(g) of the supporting statement.
Attachment A: |
42 USC 13103 - Pollution Prevention Act Section 6604. Also available at online at the US House of Representatives’ Office of the Law Revision Counsel’s US Code website
|
Attachment B: |
Screening Questionnaire for “Leaning Green” Consumer Focus Group
|
Attachment C: |
Screening Questionnaire for General Adult Consumer Focus Group
|
Attachment D: |
Moderator’s Guide for Consumer Focus Group Session
|
Attachment E: |
Survey for EPA Design for the Environment (DfE) Redesign of Visual Mark: General Adult Population Survey
|
Attachment F: |
Survey for EPA Design for the Environment (DfE) Post-Launch Awareness Test of New Visual Mark: General Adult Population Survey |
1 BLS, 2013. Employer costs per hour worked for employee compensation and costs as a percent of total compensation: Civilian workers, by major occupational and industry group, March 2013. Available at http://www.bls.gov/news.release/archives/ecec_06122013.pdf.
2 Estimates based on similar ICR packages approved by OMB, including 0990-0376: HHS/ONC, Comprehensive Communication Campaign for HITECH ACT and 0584-0523: USDA, Generic Clearance to Conduct Formative Research/CNPP
3 OPM, 2013. Salary Table 2013-DCB, Washington-Baltimore-Northern Virginia, DC-MD-VA-WV-PA. Available at http://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/2013/general-schedule/dcb_h.pdf.
Page
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| Author | RCarlson |
| File Modified | 0000-00-00 |
| File Created | 2021-01-28 |