PART A OF THE SUPPORTING STATEMENT INFORMATION COLLECTION REQUEST ( EPA ICR Number 1917.01)

IAQ Practices in Large Buildings Survey U. S. Environmental Protection Agency Office of Radiation and Indoor Air Indoor Environments Division A 1 INFORMATION COLLECTION REQUEST ( EPA ICR No. 1917.01)

U. S. Environmental Protection Agency Office of Radiation and Indoor Air Indoor Environments Division SECTION I B IDENTIFICATION OF THE INFORMATION COLLECTION 1( a) Title of the Information Collection IAQ Practices in Large Buildings Survey 1( b) Short Characterization ( Abstract)

EPA is currently working with other Federal agencies and the public, as well as with other nations, to promote effective approaches to identifying and solving indoor air quality ( IAQ)

problems. As part of this effort, EPA has developed a guide which addresses indoor air quality in large buildings entitled, " Building Air Quality: A Guide for Building Owners and Facility Managers ( BAQ)." This document provides an extensive discussion of a wide range of potential indoor air pollutants and suggests ways in which building owners and managers can improve the indoor air quality of their buildings. As a complement to the Guide, EPA has also developed a comprehensive BAQ Action Plan, which describes an eight step process for improving a building's indoor air quality. The BAQ Action Plan can be used to determine the current condition of a building's indoor air quality, as well as to successfully implement good IAQmanagement practices.

Using a seven page survey, EPA proposes to collect data from building owners and managers on their implementation of IAQ practices ( See Appendix 4). This survey will allow EPA to determine the extent to which elements of the BAQ guidance have been incorporated into building management practices throughout the United States. The Agency also wishes to determine what barriers to implementation, if any, have been incurred by building owners and managers. These data are essential for measuring the effectiveness of EPA's efforts to encourage good IAQ management practices in large buildings against the Agency's established Government Performance Results Act ( GPRA) goal. By the year 2005, EPA wishes to demonstrate a five percent increase in the number of large buildings that use good IAQ management practices. The Agency has defined large buildings to be those over 50,000 square feet. 1Government mail surveys using the business establishment as the unit of analysis typically achieve response rates ranging from 15 to 25 percent in the first stage of establishment surveys. The use of mailed prenotification notices can increase the response rate from 5 to 7 percent, while the use of follow up reminder letters has been proven to increase the total response by 4 to 8 percent ( Chun96). In addition, delivery methods which increase the perceived importance of the survey, such as certified mail, special delivery, or 2 day priority mail, have proven effective in increasing the overall response rate ( Dillman96).

This ICR will utilize prenotification and follow up reminder letters and will be distributed using 2 day priority mail service; consequently, the total response rate achieved is likely to be on the upper end of these ranges.

2EPA will target commercial survey recipients through their membership in professional organizations; government survey recipients will be identified through a listing of GSA building managers. It is not possible to filter out of the commercial listings potential survey recipients who own or manage buildings that do not meet EPA's size criteria of 50,000 square feet. Consequently, EPA estimates that 30 percent of the owners/ managers of commercial office buildings surveyed will be ineligible to participate in this ICR. EPA also estimates that 30 percent of the eligible survey recipients will respond to the initial and follow up survey mailings.

A 2 To determine its success in achieving this goal, EPA intends to survey owners and managers of commercial and government owned office buildings greater than 50,000 square feet on a variety of IAQ practices. The Agency will mail a survey and instructions for completing it to approximately 4,150 building owners and managers. Building owners/ managers will be given up to 30 days to respond. At the end of this period, a follow up letter will be sent to building owners and managers to remind them of the survey and to encourage them to participate. The initial survey will establish a baseline to determine the extent to which IAQ related practices recommended in EPA's guidance are currently utilized. After its completion, EPA will continue efforts to encourage large building owners and managers to adopt the IAQ practices outlined in the BAQ. EPA intends to conduct another survey in 2005 to assess changes in the use of these practices.

EPA expects that approximately 43 percent of the surveys will be completed1; 38 percent will be completed by owners/ managers of commercial office buildings and 51 percent will be completed by managers of Federally owned office buildings2. All survey data will be entered into a secured database designed to track the results. This database will be administered by the Building Owners and Managers Association ( BOMA) at their facility. BOMA will assist EPA in the distribution of the survey and the collection of survey results. Once all data associated with the survey has been captured, the database will be forwarded to EPA contractor personnel for maintenance at the contractor's facility.

This survey effort is expected to cost respondents $ 67,890 and involve approximately 1,796 respondents. In addition to providing information on EPA's attainment of its GPRA goal for the A 3 implementation of good IAQ building practices, EPA will use the data collected to evaluate the effectiveness of the guidance and to select initiatives that will further the implementation of IAQmanagement practices within the nation's large buildings. It is important to note that the survey is designed to measure the use of IAQ practices in buildings, rather than the indoor air quality of the buildings themselves.

The survey instrument was revised to incorporate comments received during the 60 day public comment period provided by the Federal Register Notice published on February 4, 2000. The revisions were related to word changes, duplication of questions and issues related to broadening the response and providing more clarity. These changes are described in detail in section 2( d) of Part B of the Supporting Statement and incorporated into the survey instrument in Appendix 4 of this document.

SECTION II B NEED FOR AND USE OF THE COLLECTION 2( a) Need/ Authority for the Collection Title IV of the Superfund Amendments and Reauthorization Act of 1986 ( SARA) gives EPA broad authority to research IAQ issues, develop and disseminate information on indoor air quality,

and coordinate IAQ efforts at the Federal, State, and local levels. ( Appendix 1 contains a copy of the relevant sections of this statute.) The Building Air Quality Guidance and the BAQ Action Plan were developed by EPA to assist building owners and managers in successfully implementing good IAQ management practices. Collecting data on the implementation of this guidance is necessary to determine the level of activity taken by building owners/ managers to improve indoor air quality. Survey results will also be used to better focus EPA's outreach activities to the owners and managers of large office buildings.

In addition, the Government Performance Results Act of 1996 requires that Federal agencies develop and meet specific goals to measure the effectiveness of their programs. EPA has committed to achieving a five percent increase in the number of large office buildings that use IAQ management practices by 2005. This information request will assist EPA in assessing the use of practices to improve the indoor air quality in the nation's large buildings. Not only will the survey provide the baseline for demonstrating future achievement of EPA's goal, it will also provide data on which elements of the BAQ guidance are being implemented and will help identify any areas of the guidance which require additional support or clarification from EPA. A 4 2( b) Practical Utility/ Users of the Data The information collected in this survey effort will be used by EPA to evaluate the effectiveness of its efforts to provide guidance to large building owners and managers on ways to improve indoor air quality. Specifically, the survey results will be used by EPA to: ( 1) assess the degree to which large building owners and managers are implementing the IAQ practices described in the BAQ guidance; ( 2) establish a baseline by which to demonstrate future achievement of the Agency's GPRA goal; and ( 3) identify strengths and weaknesses of the guidance in terms of the ability of large building owners and managers to implement the practices outlined in BAQ.

Section 4( b) i, Data Elements, discusses the particular data elements in the survey and the purposes of these elements.

SECTION III B NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA 3( a) Nonduplication This is the first comprehensive attempt to collect information about IAQ management practices in U. S. office buildings. Building owners and managers receiving the BAQ guidance or the BAQ Action Plan are not required to collect and/ or submit any information or data to EPA or any other government agency as a condition of their receipt of the guidance. In addition, owners and managers of large office buildings are not required to submit any information concerning a building's indoor air quality or any efforts to improve such quality to EPA or any other government agency. EPA is not aware of any commercial efforts to collect comprehensive information on the IAQ practices used in large office buildings. Therefore, this first time information collection is non duplicative of any past or ongoing information collection effort.

3( b) Public Notice Required Prior to ICR Submission to OMB EPA solicited public comments on this Information Collection Request ( ICR) between February 4, 2000 and April 4, 2000. A copy of the Federal Register notice requesting comments is attached as Appendix 2.

3( c) Consultations A 5 This ICR was completed in consultation with the following individuals:

1. Mr. Mark Skiff Vice President/ Management Service Director Grubb & Ellis Management Services, Inc. ( Vienna, VA) ( 703) 918 0226 2. Mr. Alfred Willis Facility Manager Alcatel Data Networks ( Ashburn, VA) ( 703) 724 2256 3. Ms. Susan Scott Director of Commercial Properties Southern Management Corporation ( Vienna, VA) ( 703) 902 9406 4. Mr. Doug Reed Regional Chief Engineer Stoladi Property Group ( Washington, D. C.) ( 202) 785 5801 5. Mr. Kevin Santee Safety and Environmental Team Leader Bannister Federal Complex ( Kansas City, MO) ( 816) 823 2219 6. Mr. Tim Gabrish Property Manager Ralph H. Metcalfe Building ( Chicago, IL) ( 312) 353 3460 3( d) Effects of Less Frequent Collection Since building owners and managers will only be surveyed once during the period for which this ICR will be in effect, it is not possible to collect this information less frequently. Therefore, the effects of less frequent information collection is not applicable to this request. A 6 3( e) General Guidelines This voluntary information collection conforms to the Office of Management and Budget's ( OMB) general guidelines on information collections. Under no circumstances will respondents be required to take any of the following actions:

$ Report information to EPA more than quarterly.

$ Prepare a written response to a collection of information in fewer than 30 days after receipt of a request.

$ Submit more than an original and two copies of any document.

$ Retain records for more than three years.

$ Participate in a statistical study that is not designed to produce data that can be generalized to the universe of the study.

$ Utilize a statistical data classification that has not been reviewed and approved by OMB.

$ Receive a pledge of confidentiality that is not supported by authority established in statute or regulation, that is not supported by disclosure and data security policies that are consistent with the pledge, or which unnecessarily impedes sharing of data with other agencies for compatible confidential use.

$ Submit proprietary, trade secret, or other confidential information unless EPA can demonstrate that it has instituted procedures to protect the information's confidentiality to the extent permitted by law.

3( f) Confidentiality EPA does not expect to receive confidential information from the large building owners or managers voluntarily participating in the IAQ Practices in Large Buildings Survey. However, if a respondent does consider the information submitted to be of a proprietary nature, EPA will assure its confidentiality based on the provisions of 40 CFR Part 2, Subpart B, " Confidentiality of Business Information." A 7 3( g) Sensitive Questions The IAQ Practices in Large Buildings Survey contains no sensitive questions.

SECTION IV   THE RESPONDENTS AND THE INFORMATION REQUESTED 4( a) Respondents/ SIC Codes The IAQ Practices in Large Buildings Survey will be sent to owners and managers of large office buildings. From past experience, individuals who are likely to implement IAQ management practices in these buildings are property and facility managers and building engineers. These professions fall into the following SIC codes:

6512 Operators of Nonresidential Buildings 8711 Engineering Services 4( b) Information Requested 4( b) i Data Elements The IAQ Practices in Large Buildings Survey will be sent to building owners, managers, or engineers of commercial and government office buildings greater than 50,000 square feet.

Commercial recipients will be identified primarily through membership in professional organizations; a list of government recipients will be identified separately. A copy of the survey and instructions for completing it are attached to this ICR and can be found in Appendix 4.

The survey will request the following information from respondents:

Reporting Items $ General Information: This section seeks general information about the respondents and the buildings for which they are responsible. Included in this section are questions concerning the building size, use, and age, occupancy characteristics, and maintenance activities.

$ General IAQ Management: This section seeks general information about IAQ practices used in the building. Included in this section are questions about certain building documents, including maintenance records, blueprints, and housekeeping procedures; routine building maintenance; and the respondent's familiarity with A 8 good IAQ practices.

$ Heating, Ventilation and Air Conditioning ( HVAC) Management: This section seeks detailed information about the building's HVAC system. Included in this section are questions about HVAC capacity, schedule of operation, and preventive maintenance.

$ Loading Dock and Vehicle Idling Areas: This section requests information on the proximity of outdoor air intakes to loading docks and the measures that are taken to prevent vehicle exhaust from entering the building.

$ Managing Sources of Pollution: This section seeks detailed information about possible sources of indoor air pollutants, such as cleaning products, exhaust ventilation, and tobacco smoke.

$ Housekeeping and Pest Management: This section seeks information about the building's housekeeping procedures and pest control methods.

$ Remodeling and Renovation: This section requests information about the procedures that are used to minimize the generation and migration of contaminants or odors during remodeling and construction activities.

$ IAQ Complaints and Tenant and Occupant Relations: This section requests information about procedures for addressing tenant/ occupant IAQ complaints and the level of IAQ information routinely provided to tenants/ occupants.

$ Additional Items: This section of the survey seeks feedback on what type of activities or information would help improve the building's existing IAQ program. Respondents may choose from a host of options or indicate a specific need not included on the list.

$ Remarks: The survey also provides an opportunity for respondents to offer any additional comments about IAQ management issues.

There are no record keeping items specifically required by this survey. While the survey does include questions regarding certain record keeping practices, EPA does not require building owners and managers to maintain any records related to a building's indoor air quality. In addition, any actions a building owner or manager takes to improve indoor air quality are purely voluntary. A 9 4( b) ii Respondent Activities Owners or managers who elect to participate in EPA's IAQ Practices in Large Buildings Survey will perform the following tasks:

$ Review survey instructions.

$ Compile survey information.

$ Complete survey.

$ Mail survey to EPA.

These activities represent a voluntary information collection for each building and are not customary business practices of the respondents.

SECTION V   THE INFORMATION COLLECTED   AGENCY ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT 5( a) Agency Activities Agency activities associated with the IAQ Practices in Large Buildings Survey include the following:

$ Develop survey form.

$ Pretest survey form.

$ Develop IAQ Practices in Large Buildings Survey database.

$ Populate database.

$ Distribute presurvey notification.

$ Distribute survey.

$ Collect information from respondents.

$ Review information collected and complete data entry.

$ Maintain secure database.

$ Analyze results.

$ Prepare findings.

5( b) Collection Methodology and Management The IAQ Practices in Large Buildings Survey is a seven page questionnaire which elicits multiple choice responses. The survey was peer reviewed by EPA staff and recognized IAQ professionals to ensure that the questions asked reveal sufficient information to adequately evaluate the IAQ practices implemented in large buildings. This review also ensured that the questions asked do A 10 not collect redundant information. In addition, the survey instrument was pretested on six individuals associated with the management of large office buildings ( see Section 3( c)). This pretest was conducted to ensure that the questions asked are clear and to obtain an estimate of the burden of response.

In collecting and analyzing the information associated with this ICR, EPA will use personal computers and applicable database software. EPA will ensure the accuracy and completeness of collected information by reviewing each submission. Each survey form will be assigned a unique identifier to facilitate the tracking of survey responses within the project database. EPA will enter the survey results into a Microsoft Access database and aggregate the data to monitor the implementation of good IAQ practices in large buildings. A double entry protocol will be observed throughout data entry to ensure an accuracy rate of at least 99 percent. Under this protocol, each survey form will be entered into the database twice, after which a computer program designed to identify variances in the data entered will be run. Following data entry, a final review of survey responses will be performed to identify numerical outliers in individual responses and to ensure file completeness. Blank responses and outliers will be checked against the hard copies of the survey instruments and modified within the database where appropriate.

EPA will randomly check approximately two percent of data records generated to ensure compliance with the 99 percent data entry threshold.

Results of the survey will be summarized and made available to the U. S. Congress during EPA's reporting of its GPRA goals. Additionally, the Indoor Environments Division ( IED) will report to the Regulatory Information Division on the results of the survey process and, upon request, will make copies of the survey instrument and this ICR available as a reference to other EPA Program Offices undertaking large scale survey and program evaluation efforts.

5( c) Small Entity Flexibility EPA does not believe that this ICR will have a " significant economic impact on a substantial number of small entities." The IAQ Practices in Large Buildings Survey is strictly voluntary and is intended to evaluate IAQ management practices in office buildings greater than 50,000 square feet. It is possible that some survey recipients may represent property management companies or other businesses that meet the definition of a small entity as contained in Section 601 of the Regulatory Flexibility Act. However, the Agency does not consider the relatively small burden associated with completing this voluntary survey to represent a significant economic burden to A 11 survey respondents. In addition, there are no continuing record keeping requirements associated with the survey; respondents will assume a one time, voluntary burden.

5( d) Collection Schedule Information collection will begin upon approval of this ICR and the assignment of an OMB Control Number to the survey instrument. The collection schedule is expected to follow the approximate time lines presented below.

Activity Time Line Mail prenotification letters to respondents Within 15 days of OMB approval of ICR Mail surveys to respondents Within 15 days of prenotification letters Mail follow up letters to nonrespondents 30 days after survey mailing Complete data entry of survey results 180 days after the initial survey mailing Analyze survey data 10 days after completion of data entry Report survey findings 30 days after completion of data analysis SECTION VI   ESTIMATING THE BURDEN AND COST OF THE COLLECTION 6( a) Estimating Respondent Burden This section details the estimated burden to respondents participating in the EPA IAQ Practices in Large Buildings Survey. Estimates of the time burden involved in responding to the survey were derived from the survey pretest, which provided information on the staff and time required to respond to the survey.

Tables 6.1 presents a summation of the resulting respondent burden estimates.

Table 6.1   Respondent Burden/ Cost ACTIVITIES BURDEN HOURS/ RESPONDENT Review Survey Instructions Compile Survey Information Complete Survey Mail Survey to EPA 0.3 0.7 0.7 0.1 Total 1.8 ( 108 minutes) A 12 6( b) i Estimating Respondent Costs EPA estimated respondent costs using the burden estimates presented in Section 6( a) and the average wage figures provided by the Bureau of Labor Statistics for each of the respondents'

occupational categories. The average hourly wage rates for each respondent type are as follows:

Property Managers $ 13.70 per hour Building Engineers $ 15.50 per hour Building Services/ Facilities Manager $ 25.90 per hour ( Commercial Properties) Building Services/ Facilities Manager $ 23.60 per hour ( Federal Properties)

These figures were taken from the Department of Labor's Bureau of Labor Statistics 1998 99 Occupational Outlook Handbook at http:// stats. bls. gov/ ocohome. htm.

To determine the respondent burden hours, EPA used the results of its survey pretest. The time spent on each activity was averaged across the number of pretest respondents. The range of time spent on each activity is as follows:

Review Instructions: Five to 45 minutes Compile Survey Information: 10 to 60 minutes Complete Survey 20 to 60 minutes Mail Survey to EPA Three to 15 minutes Tables 6.2 to 6.5 present the individual respondent costs associated with this ICR. The respondent costs are presented by respondent type. Table 6.6 summarizes the individual tables.

The burden costs presented below represent the time spent completing all questions on the survey.

Table 6.2   Individual Respondent Cost   Property Managers ACTIVITIES BURDEN HOURS/ RESPONDENT PROPERTY MANAGERS @ $ 13.70/ HOUR Review Instructions Compile Survey Information Complete Survey Mail Survey to EPA 0.3 0.7 0.7 0.1 $ 4.10 $ 9.60 $ 9.60 $ 1.40 Total 1.8 ( 108 minutes) $ 24.70 Table 6.3   Individual Respondent Cost   Building Engineers A 13 ACTIVITIES BURDEN HOURS/ RESPONDENT BUILDING ENGINEERS @ $ 15.50/ HOUR Review Instructions Compile Survey Information Complete Survey Mail Survey to EPA 0.3 0.7 0.7 0.1 $ 4.70 $ 10.90 $ 10.90 $ 1.60 Total 1.8 ( 108 minutes) $ 28.10 Table 6.4   Individual Respondent Cost   Building Services/ Facility Managers ( Commercial Property)

ACTIVITIES BURDEN HOURS/ RESPONDENT BUILDING SERVICES/ FACILITY MANAGERS @ $ 25.90/ HOUR Review Instructions Compile Survey Information Complete Survey Mail Survey to EPA 0.3 0.7 0.7 0.1 $ 7.80 $ 18.10 $ 18.10 $ 2.60 Total 1.8 ( 108 minutes) $ 46.60 Table 6.5   Individual Respondent Cost   Building Services/ Facility Managers ( Federally owned Property)

ACTIVITIES BURDEN HOURS/ RESPONDENT BUILDING SERVICES/ FACILITY MANAGERS @ $ 23.60/ HOUR Review Instructions Compile Survey Information Complete Survey Mail Survey to EPA 0.3 0.7 0.7 0.1 $ 7.10 $ 16.50 $ 16.50 $ 2.40 Total 1.8 ( 108 minutes) $ 42.50 Table 6.6   Summary of Individual Respondent Costs for Large Office Buildings by Respondent RESPONDENT TYPE INDIVIDUAL RESPONDENT COST Property Managers $ 24.70 Building Engineers $ 28.10 Building Services/ Facility Managers ( Commercial Properties) $ 46.60 Building Services/ Facility Managers ( Federally owned Properties) $ 42.50 Average Respondent Cost ( Commercial Properties)* $ 33.10 Respondent Cost ( Federally owned Properties) $ 42.50 * EPA has chosen to average respondent costs associated with commercially owned or  operated buildings since the Agency has no way of estimating the distribution of respondents across occupation categories.

6( b) ii Estimating Capital and Operations and Maintenance Costs A 14 EPA does not expect respondents to the IAQ Practices in Large Buildings Survey to incur any capital or operations and maintenance ( O& M) costs. This information collection is voluntary and does not require special equipment. The only potential O& M costs to be incurred would be those associated with photocopying the survey, once completed, for the respondent's records ( if desired). EPA intends to enclose an EPA flocked envelope, including postage, in which respondents may return the survey to EPA. The Agency estimates respondent O& M costs to be less than $ 1.00 per survey.

6( b) iii Capital/ Start up vs. Operating and Maintenance Costs Not applicable.

6( b) iv Annualizing Capital Costs Not applicable.

6( c) Estimating Agency Burden and Costs Table 6.7 provides the estimates of EPA's burden and costs associated with the IAQ Practices in Large Buildings Survey. Wage estimates for Agency personnel are divided into three general categories of labor: Management ( GS 15); Technical ( GS 14); and Clerical ( GS 7). EPA personnel participating in this survey effort are assumed to be management and technical personnel. Civil Service wage estimates are based on the 1999 pay scale for Washington, DC employees, and include a benefits multiplier of 1.6. EPA contractor personnel and its cooperative partner, BOMA, will also support this survey effort, and their costs will be included as an Agency burden. Wage rates used in this ICR include:

Civil Service ( Manager) $ 58.00/ Hour Civil Service ( Technical) $ 49.00/ Hour Contractor Personnel $ 60.00/ Hour BOMA Personnel $ 30.00/ Hour EPA and contractor and BOMA personnel will conduct the following activities: 3Of the 2,390 commercial survey recipients, EPA anticipates that 70 percent, or 1,673 recipients, will be eligible to participate ( i. e., they meet the survey's size requirements), and of those eligible participants, EPA anticipates that 30 percent, or 502 participants, will respond to the initial mailing.

Similarly, of the 1,888 commercial survey recipients who did not respond to the initial survey, seventy percent, or 1,322 recipients, will be eligible to participate in the follow up survey, and of those eligible participants, 30 percent, or 396 participants, will respond. 502 initial survey responses + 396 follow up survey responses = 898 total survey responses 898 total survey responses ÷ 2,390 surveys mailed = 38 percent response rate.

A 15 Table 6.7 Agency Burden/ Cost for IAQ Practices in Large Buildings Survey ACTIVITIES BURDEN HOURS Manager @ $ 58.00/ Hour Technical @ $ 49.00/ Hour Contractor @ $ 60.00/ Hour BOMA Personnel @ $ 30.00/ Hour Total Hours Develop Survey Form Pretest Survey Form Develop Implementation Database Populate Project Database Distribute Presurvey Notification Letters Distribute Surveys Distribute Reminder Letters Data enter Results Analyze Results Report Findings 20 3 5 1 0 5 0 0 16 17 900 50 40 30 32 16 16 20 160 108 787 35 245 95 1 13 1 0 250 329 0 0 24 8 16 24 8 128 100 48 1,707 88 314 134 49 58 25 148 526 502 Total Hours 67 1,372 1,756 356 3,551 Total Costs $ 3,890 $ 67,230 $ 105,360 $ 10,680 $ 187,160 In addition to the labor burden associated with the distribution of IAQ Practices in Large Buildings Survey, EPA will also incur $ 66,965 in other direct costs. These costs include supplies ( envelopes and mailing labels), postage, and delivery charges.

6( d) Estimating the Respondent Universe and Total Burden and Costs EPA anticipates distributing a survey to 4,150 building owners and managers. Of those recipients, EPA expects a return rate of 38 percent from owners/ managers of commercial office buildings3 and a return rate of 51 percent from managers of Federally owned office 4Of the 1,760 Federal survey recipients, EPA anticipates that 30 percent, or 528 recipients, will respond to the initial mailing. Similarly, of the 1,232 Federal survey recipients who did not respond to the initial survey, 30 percent, or 370 participants, will respond to the follow up mailing. 528 initial survey responses + 370 follow up survey responses = 898 total survey responses 898 total survey responses ÷ 1,760 surveys mailed = 51 percent response rate.

5EPA will obtain its commercial survey sample from membership lists of professional associations. EPA intends to survey only those owners and managers of office space greater than 50,000 square feet. However, the Agency is unable to filter from these lists those owners and managers of buildings which do not meet this size standard. Consequently, EPA estimates that approximately 30 percent of its sample frame will be ineligible to participate in its survey.

6898 commercial responses + 898 Federal responses = 1,796 total responses 1,796 ÷ 4,150 total recipients = 43 percent response rate A 16 buildings. 4 The difference in expected response rates between owners/ managers of commercial and Federally owned properties can be attributed to the estimated percentage of commercialbuilding owners and managers who will receive a survey but will be ineligible to participate. 5 Consequently, EPA estimates achieving an overall response rate of 43 percent to the IAQ Practices in Large Buildings Survey. 6 The bottom line burden hours and costs for this information collection effort are as follows:

Total Annual Burden = ( Total Hours x No. of Respondents) ÷ 3 ( 1.8 hours x 1,796 respondents) ÷ 3 = 1,078 Hours Average Individual Respondent Collection Cost = $ 33.10/ Respondent ( Commercial Office Buildings)

Individual Respondent Collection Cost = $ 42.50/ Respondent ( Federally owned Office Buildings)

Total Annual Costs for All Respondents:

[( Individual Respondent Collection Cost ( Commercial) x Number of Respondents) + ( Individual Respondent Collection Cost ( Federally owned) x Number of Respondents)] ÷ 3 [($ 33.10 x 898) + ($ 42.50 x 898)] ÷ 3 = $ 22,630 Total Hourly Burden = Respondent Hours Per Survey x Number of Respondents 1.8 x 1,796 = 3,233 Hours A 17 Total Cost:

( Individual Respondent Collection Cost ( Commercial) x Number of Respondents) + ( Individual Respondent Collection Cost ( Federally owned) x Number of Respondents)

($ 33.10 x 898) + ($ 42.50 x 898) = $ 67,890 Table 6.8 details the bottom line burden for EPA associated with this survey effort.

Table 6.8  EPA Bottom line Labor Burden NUMBER OF HOURS HOURLY RATE TOTAL COSTS 67 $ 58.00 ( Manager) $ 3,890 1,372 $ 49.00 ( Technical) $ 67,230 1,756 $ 60.00 ( Contractor) $ 105,360 356 $ 30.00 ( BOMA Personnel) $ 10,680 TOTAL 3,551 $ 187,160 6( e) i Bottom Line Burden Hours and Cost Tables Table 6.9 details the total bottom line burden ( respondent and EPA) associated with this survey effort. Table 6.6 in Section 6( c) Estimating Agency Burden and Costs and figures calculated in Section 6( d), Estimating the Respondent Universe and Total Burden and Costs, detail how these total figures were derived.

Table 6.9 B Bottom line Burden Hours and Cost BURDEN CATEGORY BURDEN COSTS BURDEN HOURS Respondent $ 67,890 3,233 hours EPA Labor $ 187,160 3,551 hours EPA Other Direct Costs $ 66,965 N/ A Total Bottom line Burden $ 322,015 6,784 hours 6( e) ii The Agency Tally See Section 6( c), Estimating Agency Burden and Costs, for information on how the bottom line Agency costs were derived. A 18 6( e) iii Variation in the Annual Bottom Line Since respondents will only participate once in the IAQ Practices in Large Buildings Survey during the clearance period requested, EPA does not expect any variation in the annual bottomline

6( f) Reasons for Change in the Burden This section is not applicable since this is a new ICR.

6( g) Burden Statement Public reporting burden for this collection of information is estimated to be about 1.8 hours or 108 minutes. This includes time for reviewing survey instructions, compiling survey information,

completing the survey, and mailing the survey to EPA. The average commercial respondent's response cost is $ 33.10. The response cost for managers of Federal office buildings is $ 42.50.

Send comments on the Agency's need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden to the Director,

Collection Strategies Division, Office of Environmental Information, ( OEI), U. S. Environmental Protection Agency MC ( 2822), 1200 Pennsylvania Ave., NW, Washington, DC 20460, and to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Officer for EPA. Include the EPA ICR Number 1917.01 in any correspondence. Part B OF THE SUPPORTING STATEMENT INFORMATION COLLECTION REQUEST ( EPA ICR Number 1917.01)

IAQ Practices in Large Buildings Survey U. S. Environmental Protection Agency Office of Radiation and Indoor Air Indoor Environments Division B 1 INFORMATION COLLECTION REQUEST ( EPA ICR No. 1917.01)

U. S. Environmental Protection Agency Office of Radiation and Indoor Air Indoor Environments Division SECTION I B SURVEY OBJECTIVES, KEY VARIABLES, AND OTHER PRELIMINARIES 1( a) Survey Objectives EPA is proposing to conduct a survey of building owners and managers to evaluate the current use of indoor air quality ( IAQ) management practices in large commercial and Federally owned office buildings. For the purposes of this survey, EPA is defining large buildings as those over 50,000 square feet. EPA has published a guide entitled, " Building Air Quality: A Guide for Building Owners and Facility Managers ( BAQ)," which details the wide range of potential indoor air pollutants and suggests ways in which building owners and managers can improve the indoor air quality of their buildings. Through this survey effort, EPA can measure the effectiveness of its current outreach activities and better target future activities to encourage large building owners and managers to adopt the IAQ practices outlined in BAQ.

EPA intends not only to survey owners and managers of large office buildings now, but also to readminister the survey in the year 2005. By so doing, EPA expects to be able to demonstrate the achievement of the Agency's Government Performance Results Act ( GPRA) goal. Between now and the year 2005, the Agency is striving to achieve a five percent increase in the number of large buildings that use IAQ management practices.

EPA expects the following issues to be addressed by the IAQ Practices in Large Buildings Survey:

Issue 1: The extent to which IAQ management practices are being used in the nation's large office buildings.

Issue 2: The barriers to implementation, if any, that have been incurred by building owners and managers in attempting to administer IAQ management practices.

Issue 3: Ways in which the Agency might better target its outreach efforts to encourage widespread adoption of the IAQ practices outlined in the BAQ by building owners and managers. B 2 1( b) Key Variables The key variables associated with this survey effort include:

$ The size, age, use, and occupancy of the building.

$ The level of knowledge possessed by building owners and managers, or their contractors, about indoor air quality and ways in which to improve it.

$ Potential sources of indoor air pollution within a particular building.

$ IAQ management practices currently being used by building owners and managers.

The most significant variable in terms of its potential influence on the survey results are the types of IAQ management practices currently being used by building owners and managers. This variable is directly related to the survey's primary objective, which is to determine the extent to which IAQ management practices are utilized in the nation's large buildings. The other variables identified may influence the likelihood that a building owner or manager will implement IAQmanagement practices and therefore may indirectly influence survey results.

1( c) Statistical Approach In response to the Government Performance Results Act ( GPRA), EPA has set a specific,

quantitative goal related to the extent to which IAQ practices are utilized in large buildings throughout the country. The primary objective in conducting the IAQ Practices in Large Buildings Survey is to measure the rate of change in the use of such practices over a certain period of time. EPA has targeted building owners and managers throughout the United States as potential recipients of its survey, since they are most likely to know what IAQ measures are currently employed as part of a facility's routine operation and maintenance. However, it is not possible to survey every large building owner or manager in the United States. Consequently,

EPA is faced with surveying a subset of the group in such a way as to allow the Agency to draw conclusions about the group as a whole from the responses received. Anecdotal information is not sufficient for this purpose, and so EPA has chosen a statistical approach for the IAQ Practices in Large Buildings Survey.

The survey asks a series of questions about the use of IAQ management practices by largebuilding owners and managers. An analysis of the results will provide EPA with a snapshot of the current use of these practices. By administering the survey now, and again in 2005, EPA can compare the results of both survey efforts and draw statistically valid conclusions concerning the change in the use of these practices. This change will then be measured against the Agency's B 3 GPRA goal. In addition, the survey responses will also provide EPA with an indication of any barriers building owners and managers may be experiencing in their attempts to implement IAQmanagement practices. This data will allow the Agency to design outreach materials and activities to assist this group in overcoming obstacles and adopting good IAQ practices.

EPA will be assisted in its survey effort by two organizations:

Building Owners and Managers Association ( BOMA) 1201 New York Avenue, NW Washington, DC 20005.

Sanford Cohen & Associates ( SC& A) 1355 Beverly Road McLean, VA 22101.

BOMA will assist EPA in distributing survey forms and instructions, responding to questions from survey recipients, and capturing survey results. SC& A will provide support to EPA in identifying survey recipients, tabulating and analyzing data, and reporting results.

1( d) Feasibility EPA has reviewed the administrative procedures necessary to conduct the IAQ Practices in Large Buildings Survey and has concluded that it is feasible to undertake the survey. In designing the survey instrument, EPA consulted IAQ professionals and conducted focus group testing to ensure that the questions asked would be easy to understand and answer. EPA has also arranged for the data to be handled by an independent company ( SC& A) to assure complete confidentiality of the responses. Furthermore, EPA has sufficient funding to conduct the survey and a contract in place with SC& A to provide the necessary logistical support.

SECTION II B SURVEY DESIGN 2( a) Target Population and Coverage EPA is targeting the owners and managers of commercial and Federally owned office buildings for participation in the IAQ Practices in Large Buildings Survey. The Agency is specifically targeting owners and managers of office buildings greater than 50,000 square feet. Many IAQ issues are related to a building's heating, ventilation, and air conditioning ( HVAC) system. EPA has chosen not to survey smaller office buildings, because the Agency's experience suggests that more consistency exists among HVAC systems in large buildings, as well as in the types of management practices employed in these buildings. This consistency will provide EPA with a B 4 better indication of why building owners and managers do or do not adopt good IAQmanagement practices than with a survey in which there is no commonality among the respondents in terms of how their buildings are managed. Consequently, EPA's GPRA goal is expressed in terms of a percentage change in the use of IAQ management practices in large office buildings.

2( b) Sample Design 2( b) i Sampling Frame 33,935 building owners or property managers comprise the sample frame for the IAQ Practices in Large Buildings Implementation Survey. EPA obtained the sampling frame for commercial office buildings from three sources:

$ The membership list of the BOMA.

$ The membership list of the International Facility Management Association ( IFMA).

$ A commercially purchased list of commercial office buildings greater than 50,000 square feet derived from electronically available tax records.

The membership lists for the trade associations are updated annually. The commerciallypurchased list was compiled in February 1998. Some duplication may exist among the three lists but will be eliminated prior to the selection of survey recipients.

The General Services Administration ( GSA) has provided EPA with a list of government owned office buildings greater than 50,000 square feet.

Survey participants may be concerned about the confidentiality of their responses. To ameliorate this concern, EPA has taken steps to ensure that Agency staff will be unable to access raw survey data. These measures are described in more detail in Section 4( b) below.

2( b) ii Sample Size EPA expects to survey 2,390 commercial building owners and managers and 1,760 Federal building managers during the period for which this ICR is in effect. In selecting its sample size,

the Agency evaluated a number of parameters including confidence levels, precision, and cost.

EPA also considered the likely response rates for a survey of this kind. EPA selected a B 5 confidence level of 95 percent and a precision rate of five percent for each sample subset. This will result in a better than four percent precision rate for the survey as a whole. The selection of these parameters, coupled with the expected response rates, led to the selection of the sample size.

EPA did consider higher precision rates. However, the Agency determined that the added cost of substantially increasing the sample size was not warranted given the survey's ultimate objective.

The sample size selected will ensure a 95 percent confidence level in the survey's results. This was considered sufficient to demonstrate the achievement of EPA's GPRA goal with a high degree of confidence. Additional precision was considered unnecessary to meet this objective.

2( b) iii Stratification Variables EPA wishes to explore any potential differences between the IAQ management practices of commercially owned buildings and those that are Federally owned. This information will assist the Agency in targeting future outreach efforts. Consequently, EPA is creating two strata for the IAQ Practices in Large Buildings Survey: commercially owned large office buildings and government owned large office buildings. Separate sampling frames will be used for each strata.

As a result of this stratification, the precision rate for the overall survey will improve.

2( b) iv Sampling Method The sample for EPA's IAQ Practices in Large Buildings Survey will be randomly generated from the two sampling frames identified in Section 2( b)( i). EPA will consolidate the three commercial listings, eliminating duplicative or incomplete information, and then randomly select 2,390 names and addresses from the master list created. EPA will also generate a random selection of 1,760 names and addresses from the list of managers of Federally owned office buildings. These names will comprise the survey's sample.

2( b) v Multi Stage Sampling EPA is not conducting multi stage sampling in the IAQ Practices in Large Buildings Survey.

2( c) Precision Requirements 2( c) i Precision Targets EPA is targeting an overall precision rate of better than four percent for determining the extent to 7Of the 2,390 initial commercial survey recipients, EPA anticipates that 70 percent, or 1,673 recipients, will be eligible to participate ( i. e., they meet the survey's size requirements), and of those eligible participants, approximately 30 percent, or 502 participants, will respond to the initial mailing. Similarly, of the 1,888 survey recipients ( 2,390  502) who did not respond to the initial survey, 70 percent, or 1,322 recipients, will be eligible to participate. Of those eligible participants, 30 percent, or 396 B 6 which IAQ management practices are utilized in large buildings. For each sample subset ( i. e.,

commercial office buildings and Federally owned office buildings) the Agency is targeting a five percent precision rate. EPA feels that these precision rates will be more than adequate to characterize any change measured between the baseline and subsequent survey as a true ( or statistically relevant) change in IAQ management practices and not a function of the margin of error.

2( c) ii Nonsampling Error EPA expects that the largest nonsampling error associated with the IAQ Practices in Large Buildings Survey will be the result of nonresponse. To minimize the potential for nonresponse,

EPA will take the following steps:

$ A presurvey notification will take place in the form of a letter from BOMA and GSA endorsing EPA's survey and encouraging survey recipients to respond.

$ EPA will send out detailed instructions with the survey and will use the IAQ InfoLine, a toll free public information service, to respond to questions about the survey.

$ The survey will be distributed in such a way as to gain the recipient's immediate attention, i. e., priority mail.

$ Survey recipients may complete the survey in writing or electronically via EPA's web page. EPA will enclose a self addressed, postage paid envelope for those who wish to submit their response by mail.

$ Follow up letters will be sent out to all respondents, along with a duplicate copy of the survey instrument, to give those who have not yet responded to the survey another opportunity to participate.

$ A tangible incentive will be offered to those responding.

Based on these steps, EPA expects a response rate of 38 percent among commercial building owners and managers7 and 51 percent among Federal building managers. 8 The difference in participants, will respond to the follow up mailing. 502 initial survey responses + 396 follow up survey responses = 898 total survey responses 898 total survey responses ÷ 2,390 surveys mailed = 38 percent response rate.

8Of the 1,760 Federal survey recipients, EPA anticipates that 30 percent, or 528 recipients, will respond to the initial mailing. Similarly, of the 1,232 survey recipients ( 1,760  528) who did not respond to the initial survey, EPA estimates that 30 percent, or 370 participants, will respond to the follow up mailing. 528 initial survey responses + 370 follow up survey responses = 898 total survey responses 898 total survey responses ÷ 1,760 surveys mailed = 51 percent response rate.

9EPA will obtain its commercial survey sample from membership lists of professional associations. EPA intends to survey only those owners and managers of office space greater than 50,000 square feet. However, the Agency is unable to filter from these lists those owners and managers of buildings which do not meet this size standard. Consequently, EPA estimates that approximately 30 percent of its sample frame will be ineligible to participate in its survey.

10898 commercial responses + 898 Federal responses = 1,796 total responses 2,390 commercial survey recipients + 1,760 Federal survey recipients = 4,150 total recipients 1,796 total responses ÷ 4,150 total recipients = 43 percent response rate 111796 total responses  15 percent incomplete responses = 1,527 complete responses 1,527 complete responses ÷ 4,150 total recipients = 37 percent response rate B 7 expected response rates between owners/ managers of commercial and Federally owned properties can be attributed to the estimated percentage of commercial building owners and managers who will receive a survey but will be ineligible to participate. 9 Consequently EPA expects to achieve an overall survey response rate of 43 percent. 10 However, given the length and nature of EPA's survey, the Agency expects that 15 percent of the responses received will contain information insufficient to measure the respondents IAQ management practices. Consequently, EPA estimates ultimately achieving a 37 percent response rate of surveys containing complete data. 11 Based on this expected response rate, EPA has selected a sample size large enough to yield the number of responses necessary to achieve a five percent precision rate and a 95 percent confidence level.

2( d) Questionnaire Design A discussion of the data elements contained in the IAQ Practices in Large Buildings Survey is included in Section 4( b)( ii) of Part A of the Supporting Statement for this ICR. The survey seeks information about the IAQ management practices employed by the building's owner or manager.

All of the questions asked are linked to the survey's objective of determining the extent to which IAQ management practices are utilized in the nation's buildings. B 8 EPA designed a questionnaire in which the respondent need only check a box to indicate the appropriate response. The survey seeks information on each of the IAQ practices which the Agency considers important in achieving good indoor air quality. Consequently, the survey is seven pages long. By using multiple choice questions, rather than fill in the blanks, the Agency has substantially reduced the amount of time necessary for the respondent to complete the survey and has ensured consistency in data response and interpretation.

The survey instrument was focus group tested and peer reviewed by IAQ professionals. These processes ensured that respondents would understand the questions asked and provide the type of data necessary to measure the Agency's objectives. The survey was designed by a statistician to ensure the reliability of the data.

The survey instrument was revised again to incorporate comments received during the 60 day public comment period provided by the Federal Register Notice published on February 4, 2000.

The revisions were related to word changes, duplication of questions and issues related to broadening the response and providing more clarity. These changes are now incorporated into the survey instrument in Appendix 4. Changes were made to the following questions:

1. In question A 8, the space categories title was changed from " Other" to " Service Space."

2. In question B 1, the word "/ team" was added after " person" to broaden the response.

3. In question B2, a new item was added to expand the list of documents: " l. Policy statements( for example, " Policy on Eating Outside of Cafeteria/ Kitchen" and " Policy on Pets or Other Animals")"

4. Question B3 was deleted as it essentially duplicates information asked for in the following question B4.

5. In former question B4 ( now B3), the word " storage", in item g., was changed to " improper storage"; and a new item,"

h. Food residues", were added to improve clarity and expand on areas of importance.

6. Former question B5 is now B4.

7. Former question B6 is now B5.

8. In question C1( a), items a3. through a5. were changed to reflect ranges of cfm currently recommended by the American Society of Heating, Refrigeration and Air Conditioning Engineers( ASHRAE).

9. In question E1, the stem and item b. were changed to address factors of efficacy and toxicity involved in choosing cleaning products and other chemicals which could be sources.

10. In the stem of question F2, we added the modifier, " recognizing that different pest control methods may be appropriate in different circumstances," to improve clarity. B 9 SECTION III B PRETESTS AND PILOT TESTS To pilot test the IAQ Practices in Large Buildings Survey, EPA selected nine building owners or property managers of commercial and Federally owned facilities. Of these, six responded to the pretest by completing and returning the survey. All six pretest respondents found the survey to be easy to understand and complete. In addition, the time it took for each respondent to locate the data and complete the survey was not considered to be overly burdensome. Consequently, EPA did not adjust the survey instrument based upon the pretest results.

SECTION IV B COLLECTION METHODS AND FOLLOW UP 4( a) Collection Methods EPA has chosen two collection methods for the IAQ Practices in Large Buildings Survey.

Survey participants may respond by returning their completed questionnaire through the U. S.

Postal Service using a self addressed, postage paid envelope supplied by EPA in the survey package. Participants may also respond via a dedicated web page sponsored by EPA for the purposes of collecting this data. These two collection methods were selected to facilitate participant response and were considered to be cost effective. Because of the potential concern for confidentiality on the part of building owners and managers, EPA chose not to conduct telephone interviews.

4( b) Survey Response and Follow Up The target response rate for the IAQ Practices in Large Buildings Survey is 43 percent. The Agency expects a 38 percent response rate from commercial building owners and managers and a 51 percent response rate from managers of Federal buildings. Actual response rate will be measured using the following formula:

Response Rate = Number of Responses ÷ Number of Survey Recipients A tangible incentive will be offered to all survey participants. In addition, follow up reminder letters will be sent to all survey recipients within 30 days of the original mailing. The reminder letter will include a duplicate copy of the survey and a cover letter explaining the importance of the survey and strongly encouraging recipients who have not yet responded to participate. EPA's cooperative partner, BOMA, will be responsible for tracking survey response, entering survey results into the program database, maintaining the data in a secured environment and providing quality assurance/ quality control of all survey activities. BOMA will ensure the accuracy and B 10 completeness of collected information by reviewing each submission prior to data entry. Each survey form will be assigned a unique identifier to facilitate the tracking of survey responses within the project database. Survey results will be entered into a Microsoft Access database, and the data will be aggregated to monitor the implementation of good IAQ practices in large buildings. A double entry protocol will be observed throughout data entry to ensure an accuracy rate of at least 99 percent. Under this protocol, each survey form will be entered into the database twice, after which a computer program designed to identify variances in the data entered will be run. Following data entry, a final review of survey responses will be performed to identify numerical outliers in individual responses and to ensure file completeness. Blank responses and outliers will be checked against the hard copies of the survey instruments and modified within the database where appropriate. BOMA will randomly check approximately two percent of data records generated to ensure compliance with the 99 percent data entry threshold.

SECTION V B ANALYZING AND REPORTING SURVEY RESULTS 5( a) Data Preparation Before data are entered, each survey will be visually checked to ensure its completeness.

Incomplete surveys will be considered nonresponses. Only those survey response forms evaluated as " complete" will be entered into the IAQ Practices in Large Buildings Survey database. EPA expects that 85 percent of the surveys received will contain sufficient information to evaluate the respondent's IAQ management practices ( i. e., are " complete"). Consequently, EPA estimates the true survey response rate to be closer to 37 percent.

5( b) Analysis The data obtained through this survey will be aggregated and analyzed for the purpose of establishing the base line necessary to measure EPA's GPRA goal. In addition, data collected for commercial buildings will be analyzed separately from that collected for Federal office buildings to identify any differences in IAQ management practices that may exist between the two types of facilities. Data will be tabulated for each section of the questionnaire based on the number of responses to each question. For example:

Table 5.1 B Frequency of Walkthrough Inspections SOURCE AT LEAST QUARTERLY AT LEAST YEARLY EVERY 1 5 YEARS 5 YEARS OR MORE DON'T INSPECT Odors Visible Fungal Growth B 11 Evidence of Moisture in Inappropriate Locations Poorly Maintained Filters or other HVAC Equipment Uncomfortable or Uneven Temperatures or Humidity Evidence of Inadequate Ventilation Improper Storage of Cleaning and Maintenance Products Each table will include an estimate of the relative error associated with the data reported.

5( c) Reporting Results The results of the survey will be compiled into a summary document. This document will be made available to all survey participants, as well as to BOMA and IFMA. Depending on the demand for the survey results, EPA may choose to distribute limited copies through the IAQ InfoLine. The Agency may also explore the possibility of making the summary report available through the National Technical Information Service ( NTIS). Raw survey data will be maintained by the contractor, SC& A, and will remain unavailable to the public or the Agency. APPENDIX 1 Title IV of the Superfund Amendments and Reauthorization Act of 1986 ( SARA) 1 1 APPENDIX 1 Title IV of the Superfund Amendments and Reauthorization Act of 1986 ( SARA)

Public Law 99 499, Title IV, October 17, 1986, 100 Stat. 1758, provided that:

SEC. 401. SHORT TITLE.

This Title may be cited as the ` Radon Gas and Indoor Air Quality Research Act of 1986'

SEC. 402. FINDINGS.

The Congress finds that:

( 1) High levels of radon gas pose a serious health threat in structures in certain areas of the country.

( 2) Various scientific studies have suggested that exposure to radon, including exposure to naturally occurring radon and indoor air pollutants, poses a public health risk.

( 3) Existing Federal radon and indoor air pollutant research programs are fragmented and under funded.

( 4) An adequate information base concerning exposure to radon and indoor air pollutants should be developed by the appropriate Federal agencies.

SEC. 403. RADON GAS AND INDOOR AIR QUALITY RESEARCH PROGRAM.

( a) Design of Program. The Administrator of the Environmental Protection Agency shall establish a research program with respect to radon gas and indoor air quality. Such program shall be designed to

( 1) gather data and information on all aspects of indoor air quality in order to contribute to the understanding of health problems associated with the existence of air pollutants in the indoor environment; APPENDIX 2 Draft Federal Register Notice 2 1 U. S. ENVIRONMENTAL PROTECTION AGENCY Agency Information Collection Activities: Proposed Collection; Comment Request; IAQ Practices in Large Buildings Survey AGENCY: U. S. Environmental Protection Agency ( EPA).

ACTION: Notice.

SUMMARY: In compliance with the Paperwork Reduction Act ( 44 U. S. C. 3501 et seq.), this notice announces that EPA is planning to submit the following proposed Information Collection Request ( ICR) to the Office of Management and Budget ( OMB): IAQ Practices in Large Buildings Survey, EPA ICR Number 1917.01. Before submitting the ICR to OMB for review and approval, EPA is soliciting comments on specific aspects of the proposed information collection as described below.

DATES: Comments must be submitted on or before April 4, 2000.

ADDRESSES: To obtain a copy of the ICR without charge, contact: Mr. Lee Salmon, Indoor Environments Division, Office of Radiation and Indoor Air, U. S. Environmental Protection Agency, 401 M Street, S. W., ( 6607J), Washington, D. C. 20460. A copy of the ICR can also be downloaded off the Internet at http:// www. epa. gov/ icr; refer to EPA ICR No. 1917.01.

FOR FURTHER INFORMATION CONTACT: Mr. Lee Salmon by telephone at ( 202) 564 9451 or by e mail at salmon. lee@ epa. gov.

SUPPLEMENTARY INFORMATION:

Affected entities: Entities potentially affected by this action are selected owners and managers of office buildings over 50,000 square feet. Survey recipients were selected from the membership lists of the Building Owners and Managers Association ( BOMA) and the International Facilities Management Association ( IFMA), as well as a list of commercial office buildings greater than 50,000 square feet generated from electronically available tax records. Federally owned properties were selected by EPA in consultation with the General Services Administration ( GSA). 2 2 Title: IAQ Practices in Large Buildings Survey ( EPA ICR No. 1917.01) expiring / / .

Abstract: EPA is currently working with other Federal agencies and the public, as well as with other nations, to promote effective approaches for identifying and solving indoor air quality ( IAQ) problems. As part of this effort, EPA has developed a guide which addresses indoor air quality in large buildings entitled," Building Air Quality: A Guide for Building Owners and Facility Managers ( BAQ)." This document provides an extensive discussion of a wide range of potential indoor air pollutants and suggests ways in which building owners and managers can improve the indoor air quality of their buildings. As a complement to the Guide, EPA has also developed a comprehensive BAQ Action Plan, which describes an eight step process for improving a building's indoor air quality. The BAQ Action Plan can be used to determine the current condition of a building's indoor air quality, as well as to successfully implement good IAQ management practices.

Using a seven page survey, EPA proposes to collect data from building owners and managers.

( See Appendix 4 of the Supporting Statement). This survey will allow EPA to determine the extent to which elements of the BAQ guidance have been incorporated into building management practices throughout the United States. The Agency also wishes to determine what barriers to implementation, if any, have been incurred by building owners and managers. These data are essential for measuring the effectiveness of EPA's efforts to encourage good IAQ management practices in large buildings against the Agency's established Government Performance Results Act ( GPRA) goal. By the year 2005, EPA wishes to demonstrate a five percent increase in the number of large buildings ( i. e., over 50,000 square feet) that use good IAQ management practices.

To determine its success in achieving this goal, EPA intends to survey owners and managers of commercial and government owned office buildings greater than 50,000 square feet on a variety of IAQ practices. The Agency will mail a survey and instructions for completing it to approximately 4,150 building owners and managers. Building owners/ managers will be given up to 30 days to respond. At the end of this period, a follow up letter will be sent to building owners/

managers to remind them of the survey and to encourage them to respond. The initial survey will establish a baseline for the use rate of IAQ related practices recommended in EPA's guidance.

After its completion, EPA will continue efforts to encourage large building owners and managers to adopt the IAQ practices outlined in BAQ. EPA intends to conduct another survey in 2005 to assess changes in the use of these practices. 2 3 EPA does not expect to receive confidential information from the building owners and managers voluntarily participating in the IAQ Practices in Large Buildings Survey. However, if a respondent does consider the information submitted to be of a proprietary nature, EPA will assure its confidentiality based on the provisions of 40 CFR Part 2, Subpart B, " Confidentiality of Business Information."

A Federal 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 numbers for EPA's regulations are listed in 40 CFR Part 9 and 48 CFR Chapter 15.

The EPA would like to solicit comments to:

( i) evaluate whether the proposed collection of information is necessary for the proper performance of the functions of the agency, including whether the information will have practical utility.

( ii) evaluate the accuracy of the Agency's estimate of the burden of the proposed collection of information, including the validity of the methodology and assumptions used.

( iii) enhance the quality, utility, and clarity of the information to be collected.

( iv) minimize the burden of the collection of information on those who are to respond, including through the use of appropriate automated electronic, mechanical, or other technological collection techniques or other forms of information technology, e. g., permitting electronic submission of responses.

Burden Statement: EPA expects to mail surveys to approximately 4,150 building owners and managers. EPA expects approximately 43 percent of those surveyed to respond to this information collection request. Over three years, EPA estimates that the burden to building owners and managers who respond to the survey will be approximately 3,233 hours. Burden means the total time, effort, or financial resources expended by persons to generate, maintain,

retain, or disclose or provide information to or for a Federal agency. This includes the time needed to review instructions; develop, acquire, install, and utilize technology and systems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing ways to comply with any previously applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information;

and transmit or otherwise disclose the information. 2 4 This survey effort is expected to cost the respondents approximately $ 67,890. Respondents will incur no capital or start up costs and the only operation and maintenance component of the survey will be the cost to photocopy the survey once completed ( if desired). Burden and cost estimates for the future administration of the IAQ Practices in Large Buildings Survey will be provided at the time this ICR is renewed, but they are expected to be similar to those provided in this Federal Register notice.

Dated: ________________ [ Signature of Program Official] [ Typed Name of Program Official] APPENDIX 3 Sampling Frame for EPA's IAQ Practices in Large Buildings Survey 3 1 APPENDIX 3 The Sampling Frame EPA used three sources of data to create the sampling frame for large, commercial, office buildings. The membership list of BOMA contains the names and addresses of its 14,334 commercial members. This list was last updated in the Fall of 1999. The membership list of IFMA contain the names and addresses of its 10,000 commercial members. This list is updated weekly. These two trade associations represent the majority of commercial property owners and managers in the United States. These membership lists may overlap, and they do not contain any distinction based on the size of the building. EPA will eliminate any duplication between the two lists prior to conducting the survey and has factored into its anticipated response rate a percentage of survey respondents likely to be ineligible based on the size requirements of the survey.

The Agency also purchased a listing of owners of commercial office space greater than 50,000 square feet from DataQuick, a commercial listing service. This list of 7,601 names,

addresses, and telephone numbers was compiled using electronically available tax record information. This list was created in 1998 and has not been updated since.

To create the sampling frame for large Federally owned office buildings, EPA obtained a listing of 2,000 Federally owned buildings from GSA. APPENDIX 4 IAQ Practices in Large Buildings Survey Survey Instructions and Questionnaire 4 1 Dear [ Insert name or title]

The U. S. Environmental Protection Agency ( EPA) is conducting a voluntary survey to determine the use of indoor air quality ( IAQ) management practices in office buildings over 50,000 square feet. You have been randomly selected to participate in this survey. The enclosed survey asks a series of questions concerning the size, use, and occupancy rate of the building for which you are responsible, as well as operation and maintenance practices that you employ which may have an impact on the building's indoor air quality. This information will be used to gain some insights into the extent to which IAQ management practices are implemented in office buildings across the country.

There are no " right" or " wrong" answers to the questionnaire. We are interested in your honest responses. These will help the Agency design future public information materials and outreach efforts. Many of the standard maintenance procedures you currently employ may have a positive impact on your building's indoor air quality. On the other hand, there may be some IAQmanagement practices which are not appropriate for your building. The survey does not request information on the actual indoor air quality of your building. Attached is a copy of the survey burden statement for your reference.

Your responses will be kept confidential. EPA has arranged for an independent company to receive and summarize the survey data. In this way, you can be assured that neither EPA, nor any other government agency, will have access to your individual questionnaire.

We appreciate the time you take in completing the survey. To thank you for your efforts, you will receive a free copy of EPA's software, " IBEAM". This software package identifies buildingmanagement practices that will improve indoor air quality and will assist you in determining their impact on your bottom line.

We have enclosed a self addressed, postage paid envelope for your convenience. Thank you for your time and your commitment to indoor air quality. If you have any questions concerning the survey, or indoor air quality in general, please feel free to call IAQ INFO at 1 800 438 4318.

Sincerely,

Lee Salmon Office of Radiation and Indoor Air Attachment: 4 2 BURDEN STATEMENT The public reporting and record keeping burden for this collection of information is estimated to average 1.8 hours per response. Burden means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency. This includes the time needed to review instructions; develop, acquire, install, and utilize technology and systems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjusting the existing ways to comply with any previously applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information. 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.

Send comments on the Agency's need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including through the use of automated collection techniques to the Director, Collection Strategies Division, Office of Environmental Information, U. S. Environmental Protection Agency ( 2822), 1200 Pennsylvania Avenue, NW, Washington, D. C. 20460. Include the OMB control number in any correspondence. Do not send the completed survey to this address. OMB Control Number  Expiring Date xx/ yy / zz 4 3 IAQ Practices in Large Buildings Survey Name: ( Optional) Building Location: City Title: ( Optional) State Phone Number: ( Optional) Zip Code Instructions: If you operate/ maintain more than one office building over 50,000 square feet, choose ONE that is most typical ( or with which you are most familiar) of the office buildings you manage to answer all of the questions in this survey. Please provide the following characteristic information for the building which you have selected for this survey:

How many office buildings more than 50,000 square feet do you manage or own?

( 2) General Information A1. What is your primary job? ( Check the one that most closely matches your responsibilities) a.

Owner b.

Facility Manager c.

Property Manager d.

Building Engineer e.

Other ( please describe) A5. How many people occupy this building on an average workday? a.

Less than 250 b.

250 499 c.

500 999 d.

1000 2499 e.

2500 or more A2. What is the gross square footage of this office building? a.

Less than 50,000 b.

50,000 99,999 c.

100,000 299,999 d.

300,000 599,999 e.

600,000 or more A6. In what year was the original construction of this building completed? ________

A7. In what year was the last major renovation completed? Architectural ( interior) _______ Mechanical _______ 4 4 A3. What best describes this building's ownership? a.

Government owned b.

Non government owned A8. Please indicate the percentage of the following space categories in this building: a. Office Space % b. Retail Space % c. Other % ( See below) Total 100 %

Service Space: ( check all that apply)

Health Care ( for example, doctor/ dentist office)

Food Service

Scientific Lab

Dry Cleaning

Hair Salon

Computer Lab/ Room

Printing

Photo Processing

Child care

Other ( please describe) A4. What best describes this building's occupancy? ( Check items a. and b. as applicable)

a.

Owner occupied b.

Non owner occupied Check one: c.

Single tenant d.

Multi tenant Complete: e. Occupancy level ______%

A9. Who performs the following activities? ( Check all that apply) In house Contractor Tenant a. HVAC operations

b. HVAC controls ( for example, set point adjustments)

c. HVAC regular maintenance ( for example, filter replacement)

d. HVAC major maintenance ( for example, motor replacement)

e. Building maintenance ( for example, painting)

f. Remodeling ( for example, tenant improvements)

g. Housekeeping / Cleaning

h. Pest control

B. General Indoor Air Quality ( IAQ) Management B1. Has a person/ Team been designated as the Indoor Air Quality ( IAQ) Manager or Coordinator for this building? a.

Yes b.

No B2. Are the following building documents ( written or electronic) kept on file and accessible? ( Check the most appropriate response for each item, a. through k.)

Yes No Don't Know Not Applicable a. Manufacturer's operating instructions for the HVAC system

c. HVAC system preventive maintenance plan including equipment maintenance schedule

c. Historical maintenance records for the HVAC system

d. HVAC equipment and control system documentation ( for example, operating schedules, set points and ranges)

e. Schedules and standardized procedures for facility operations and maintenance ( for example, roof repair, plumbing)

B2. Are the following building documents ( written or electronic) kept on file and accessible? ( Check the most appropriate response for each item, a. through k.)

4 5 f. Drawings of interior building renovations, including information on major space use changes ( for example, tenant build out, office space converted to laboratory, significant increase or decrease in occupancy)

g. Architectural and mechanical ` as built' blueprints

h. Material Safety Data Sheets ( MSDSs) for the products used in this building

i. Housekeeping procedures or contract ( including details on proper use, storage and purchase of cleaning and maintenance materials)

j. Procedures for responding to IAQ complaints

k. Pest control procedures or contract

l. Policy statements ( for example, " Policy on Eating Outside of Cafeteria/ Kitchen" and " Policy on Pets or Other Animals")

4 6 B3. How frequently do you, or does your contractor, inspect for the following during a walkthrough inspection? ( Check all that apply) At Least Quarterly At Least Yearly Every 1 5 Years 5 Years or More Don't Inspect a. Odors

b. Visible fungal growth ( mold or mildew)

c. Evidence of moisture in inappropriate locations ( leaks, staining, or discoloration of building materials)

d. Poorly maintained filters or other HVAC equipment

e. Uncomfortable or uneven temperatures or humidity

f. Evidence of inadequate ventilation ( use of personal fans, redirected vents and diffusers)

g. Improper storage of cleaning and maintenance products

h. Food residues

B4. How do building operation and maintenance staff learn about IAQ practices? ( Check all that apply) a. Training a1.

U. S. Environmental Protection Agency ( EPA) sponsored courses on IAQ a2.

Other formal IAQ training courses a3.

Informal IAQ training courses b. Reading IAQ reference materials b1.

EPA's Building Air Quality: A Guide for Building Owners and Facility Managers b2.

EPA's Building Air Quality Action Plan b3.

Other IAQ reference materials c.

No IAQ training or reference materials are provided to staff B5. If you use contractors for building operations and maintenance, are they trained in IAQ practices? ( Check one answer for each item below)

Yes No Don't Know a. Housekeeping b. HVAC Maintenance c. Pest Control d. Renovation/ Remodeling

4 7 C. HVAC Management C1( a). At a minimum, how much outdoor air, on average, are the air handlers set to deliver during the heating and cooling seasons? ( Check one item for each season) Heating Season Cooling Season a1. 5 cubic feet per minute ( cfm) or less per occupant

a2. Between 6 and 10 cfm per occupant

a3. Between 11 and 14 cfm per occupant

a4. Between 15 and 19 cfm per occupant

a5. 20 cfm or more per occupant

a6. I don't know

C1( b). Is the outdoor air flow rate the maximum practical amount with the existing HVAC system capacity? ( Check one item for each season) Heating Season Cooling Season b1. Yes

b2. No

b3. I don't know

C2. Is the actual amount of outside air that each air handler is delivering periodically measured? ( Check one) a.

Yes b.

No C3. A written Preventive Maintenance ( PM) plan exists for the following: ( Check all that apply)

Yes No N/ A a. Outdoor air intakes

b. Air distribution dampers

c. Air filters

d. Drain Pans

e. Heating and cooling coils

f. Interior of air handlers

g. Fan motor and belts

h. Air humidification

i. Cooling tower

j. Air distribution pathways and VAV boxes

k. HVAC system controls

l. Economizers

m. Exhaust systems

C4. The HVAC operating schedule provides that delivery of outdoor air occurs: ( Check one item for each season) Heating Season Cooling Season a. One hour or more before most occupants arrive

b. Less than one hour before most occupants arrive

c. At the same time most occupants arrive

d. After most occupants arrive

e. 24 hour continuous operation

4 8 D. Loading Dock and Vehicle Idling Areas D1. Are outdoor air intakes located near loading docks or other areas where vehicles idle? a.

Yes

Continue to item D2 b.

No

Skip to item E1 c.

Don't know

Skip to item E1 D2. Vehicle exhaust is prevented from entering the building through outdoor air intakes and building openings by: ( Check the most appropriate response for each item)

Yes No Don't Know a. Physical barriers to airflow into building ( for example, doors and curtains)

b. Pressurization of building at loading dock

c. Depressurization or ventilation of loading dock area

d. A non idling policy in effect

E. Managing Sources of Pollution E1. The choice of cleaning products and other chemicals used in this building may require a balance between efficacy ( for example, the ability to clean) and toxicity. Do you perform any of the following? ( Check the most appropriate response for each item)

Yes No Don't Know a. Routinely reviewing MSDSs or similar information to assess a product's potential impact on indoor air quality

b. Specifically considering toxicity, irritancy, allergic response, or similar factors when deciding on which products to use

c. Ensuring proper storage

E2. Exhaust ventilation is provided and operational in: ( Check the most appropriate response for each item)

Yes No Don't Know a. Mail rooms

b. Chemical storage rooms

c. Copy rooms

d. Custodial closets

e. Printing facilities

f. Other areas ( please specify)

E3. Which best describes the smoking policy in this building? ( Check one) a.

Smoking prohibited throughout building

Skip to item F1 b.

Smoking allowed in designated areas only c.

Smoking unrestricted E4. Designated smoking areas are: ( Check all that apply) a.

Separately ventilated and exhausted to the outside b.

Ventilated with 60 cfm per occupant or more c.

Kept under negative pressure d.

Not specially ventilated 4 9 F. Housekeeping and Pest Management F1. Are the following elements included in written housekeeping procedures or contracts? ( Check the most appropriate response for each item, a. through f.)

Yes No Don't Know a. Maintaining files on current products used in building, including MSDSs

b. Proper storage of cleaning and other hazardous materials

c. Proper use, mixing and dilution of cleaning products

d. Eliminating attractants ( for example, food) for insects and pests

e. Proper instruction of building staff on above procedures

f. Posting procedures for housekeeping staff in the appropriate language ( for example, Spanish)

F2. Recognizing that different pest control methods may be appropriate in different circumstances, which best describes your pest control methods, whether performed by in house or contractor personnel? ( Check one) a.

Use only chemical methods b.

Use mostly chemical methods c.

Use only non chemical methods d.

Use mostly non chemical methods G. Remodeling and Renovation G1. The following procedures are used ( or required of contractors) to minimize the generation and migration of contaminants or odors to occupied areas of the building during remodeling and renovation activities: ( Check all that apply)

Yes No Don't Know a. Designs and construction activities are reviewed for possible occupant impact before work begins on remodeling or renovation projects

b. Work is scheduled during periods of minimum occupancy

c. Air pressure is provided in order to isolate work areas

d. Lower emitting work processes are used ( for example, wet sanding dry wall)

e. Specialized cleaning procedures are used ( for example, use of HEPA vacuums)

f. Filters and ventilation equipment are protected and maintained

g. Emissions from new furnishings and materials are minimized ( for example, buying lower emitting products and airing out furnishings before installation)

h. Physical barriers are used to isolate work areas

i. Supplemental ventilation is provided in work areas during construction

j. A post construction product off gassing period is provided prior to occupancy

G2. The special procedures, used or required of contractors, in item G1, which protect occupants from IAQ pollutants during construction or buildout, are: ( Check all that apply)

Yes No Don't Know a. Written and on file

b. Posted in public places

c. Distributed to contractors and appropriate staff

d. Explained verbally to buildings staff and occupants

4 10 G3. Which best describes your painting policy?

( Check one) a.

Use standard off the shelf paint b.

Use primarily low Volatile Organic Compound ( VOC) emitting paint ( Check one) c.

Paint anytime that is convenient d.

Paint mostly during unoccupied hours ( Check one) e.

Provide no special ventilation during painting f.

Provide increased outdoor air ventilation or directly exhaust air to the outdoors during painting H. IAQ Complaints and Tenant and Occupant Relations H1. Activities involved in responding to IAQ complaints include: ( Check one for each item) Yes No a. Notifying occupants about how to file a complaint

b. Logging complaints into your existing work order system

c. Implementing remedial action, if necessary, to resolve IAQ complaints

d. Following up to determine if the problem has been resolved

e. Providing feedback about the occupant's complaint in a timely manner

f. Maintaining a historical record of IAQ complaints

g. Training building staff on complaint procedures

H2. Tenants and/ or occupants are routinely informed about the conditions affecting building operations ( for example, pest control advisories, planned major renovation and remodeling, major or unscheduled maintenance): ( Check one) a.

Yes b.

No I. Additional Items I1. What would help you improve your existing IAQ program? ( Check all that apply) a.

Technical information b.

IAQ training c.

On site consultation d.

Case studies on successful IAQ programs e.

Cost/ benefit information f.

More resources g.

More interest from occupants, staff, contractors h.

More interest/ support from owner/ manager I.

Other ( please describe) j.

No help needed Remarks: ______________________________________________________________________________________________ ______________________________________________________________________________________________ ______________________________________________________________________________________________ ______________________________________________________________________________________________ ______________________________________________________________________________________________ APPENDIX 5 Bibliography . 5 1 Bibliography Chun96 Chun, Y. I. And Robertson, K. W., ` Reducing nonresponse in business surveys', American Statistical Association Proceedings of the Section on Survey Research Methods, 1996, pp. 980 985.

Dillman96 Dillman, D. A., ` Token financial incentives and the reduction of nonresponse error in mail surveys', American Statistical Association Proceedings of the Section on Government Statistics, 1996, pp. 200 205.