Attachment L- Public Comment

August 27, 2021
Linda Rutsch
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)
Dear Ms. Rutsch,
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,

Steven Bennett, Ph.D.
Executive Vice President, Scientific & Regulatory Affairs
Household & Commercial Products Association

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