	INFORMATION COLLECTION REQUEST (ICR)

	SF-83 SUPPORTING STATEMENT

	ENVIRONMENTAL PROTECTION AGENCY

	STRATOSPHERIC OZONE PROTECTION

1.   Identification of Information Collection

a)   Title: Information on Exposure to n-Propyl Bromide under the
Significant New Alternatives Policy (SNAP) Program (OMB Control Number:
2060-       )

b)   Short Characterization

Title VI of the Clean Air Act Amendments of 1990 (the Act) implements
the obligation of the United States under the Montreal Protocol to phase
out the use of ozone-depleting substances.  Section 612 of Title VI
establishes as U.S. policy the requirement that Class I and Class II
ozone-depleting substances shall be replaced, to the maximum extent
practicable, by chemicals, product substitutes, or alternative
manufacturing processes that reduce overall risks to human health and
the environment.

EPA developed its Significant New Alternatives Policy (SNAP) program to
fulfill the requirements of Section 612.  Section 612(c) requires EPA to
enact rules making it unlawful to replace any Class I or II substance
with any substitute that the Administrator determines may present
adverse effects to human health or the environment where an alternative
has been identified that (1) reduces the overall risk to human health
and the environment, and (2) is currently or potentially available.

Section 612(c) also requires EPA to publish a list of the substitutes
prohibited for specific uses.  EPA must publish a corresponding list of
acceptable alternatives for specific uses as well.

	

EPA issued regulations on March 18, 1994, in 59 FR 13043, which are
codified at 40 CFR Part 82, Subpart G (Section 82.170 et seq.),
establishing the SNAP program.  Information required to be collected
under previous SNAP regulations is currently approved by OMB for use
through October 31, 2007 under OMB control number 2060-0266.

In the most recent proposed rule prepared for the SNAP program, EPA
does not propose any information collection requirements.  The proposal
would allow the use of n-propyl bromide without restriction in solvent
cleaning, would address its use only in a single facility using coatings
with n-propyl bromide, and would prohibit the use of n-propyl bromide in
aerosols and adhesives.

The proposal also mentions and takes comment on the rejected option of
listing the chemical n-propyl bromide as an acceptable substitute
subject to use conditions that users of n-propyl bromide in aerosol
solvents and adhesives must (1) meet a  exposure limit of no more than
20 ppm on an 8-hour time-weighted average, (2) must monitor workers for
exposure initially and periodically, and (3) must keep records of worker
exposure for up to three years from the date of measurement.  Periodic
monitoring would normally be performed every six months for facilities
where all measurements during initial monitoring are at or below the 
exposure limit of 20 ppm.  Periodic monitoring may be eliminated if all
measurements during initial testing are at 10 ppm or below.  In
addition, EPA took comments on provisions that would require new
monitoring if major changes occur that could increase exposure.  The
recordkeeping requirement is for the purpose of demonstrating compliance
with the regulatory requirement for exposure.  End users would need to
keep records to demonstrate that workers are not being exposed in excess
of the exposure limit.  Because this requirement is not explicitly
listed in the currently approved ICR for the entire SNAP program, and in
order to give the public an opportunity to comment on the burden of a
potential regulatory option, EPA is requesting approval for this
additional ICR.  The burden estimate only applies to an option for
comment, and not to the proposed regulation.

2.   Need for and Use of the Collection 

a)   Authority for the Collection

Information required to be collected under the SNAP program is intended
to fulfill the mandate in Section 612(c) of identifying acceptable
substitutes that can serve as replacements for ozone-depleting
substances being phased out under the Act, as well as unacceptable
substances which may not be used as replacements for ozone-depleting
substances being phased out under the Act.  EPA is proposing to
determine that n-propyl bromide may be used by a single user of coatings
and must not be used in aerosol solvents or adhesives.  The Agency also
provides for comment an option that would find n-propyl bromide
acceptable subject to meeting regulatory use conditions for aerosols and
adhesives, because if n-propyl bromide exposures exceed the exposure
limit, it is more hazardous to public health than other alternatives
available.  The proposed regulation for listing of n-propyl bromide is
listed in Appendix A.  Section 612 (42 U.S.C. 7671k) is attached as
Appendix B.  EPA(s implementing regulations (40 CFR Part 82, Subpart G,
Sect. 82.170 et seq.) are attached as Appendix C. 

b)   Use/Users of the Data

EPA's Regional offices and Office of Enforcement and Compliance
Assurance would use the data to determine compliance with the regulatory
use condition.  In addition, users would benefit from the information
because they can determine if further steps are necessary to protect
workers.

3.   Non-duplication, Consultations, and Other Collection Criteria 

a)   Non-duplication	

The specific information requested by this notice is not currently
collected by EPA or any other government agency. In some cases,
suppliers of n-propyl bromide assist their customers in obtaining
exposure data; these data could be used to meet the requirements of the
rule to avoid duplication with information available in the private
sector.

b)   Consultations

In preparing to prepare this information collection request, EPA
reviewed information for a similar requirement under other federal
regulations (29 CFR 1910.1052(d)).  EPA also consulted with the
Occupational Safety and Health Administration (OSHA) for guidance on
exposure monitoring.

c)   Effects of Less Frequent Collection

If information were collected less frequently, it would not be possible
to determine if the end user is in compliance. Further, users of
n-propyl bromide would be at greater risk of adverse health effects if
they do not know their workplace exposure levels.  

EPA mentions two approaches to the use conditions that reduce the total
data collection burden.  One allows relief from periodic monitoring
requirements for a user that demonstrates low exposure at their facility
(10 ppm or less).  The other allows for representative sampling of
workers using n-propyl bromide, rather than sampling of every exposed
worker. 

d)   General Guidelines 

This rule does not exceed any of the guidelines.

e)   Confidentiality and Sensitive Questions 

i)   Confidentiality

The physical records that end users keep on file are not readily
available to the public, but they are considered non-confidential.  The
records are not commercially sensitive.  

ii)  Sensitive Questions

This section does not apply because the regulation and the associated
information collection request do not seek information of a sensitive
nature.

4.   The Respondents and the Information Requested 

a)   Respondents

Respondents for the recordkeeping requirement include users of
substitutes for ozone-depleting substances.  Principally, these
respondents are in the following major categories of industry groups, by
NAICS subsector or code:

NAICS code or subsector	Description of regulated entities

326150	Urethane and other foam product (except polystyrene)
manufacturing

334	Computer and Electronic Product Manufacturing

335	Equipment Appliance, and Component Manufacturing

336	Transportation Equipment Manufacturing

337	Furniture and Related Product Manufacturing



b)   Information Requested 

i)   Data Items (for recordkeeping requirements):

EPA has based the estimated respondent burden and cost on typical
periods for completing tasks and costs for monitoring equipment for each
anticipated user of n-propyl bromide.  To the extent that companies
choose to comply by switching to another chemical or that chemical
suppliers already provide materials and analysis for exposure monitoring
to their customers, the estimates contained in this analysis may
overestimate the respondent burden and cost. 

Records of worker exposure levels to n-propyl bromide, in parts per
million over an 8-hour time-weighted average.

Method used to measure worker exposure levels.

There is no specific format for these records.

ii)  Respondent Activities

There are limited activities required of respondents:

1)   Obtain exposure monitoring badges or other monitoring equipment.

2)   Perform initial exposure monitoring with the badges within 90 days
of finalization of the rule.

3)   Send the badges to a laboratory for analysis.

4)	   Ensure that workers use the badges at the prescribed frequency
(e.g., once every six or twelve months).

5)   Keep records of the exposure information.

Some suppliers of n-propyl bromide products already carry out activities
1 and 3 for their customers.

The proposal takes comment on keeping records for up to three years. 
Under OSHA’s requirement for keeping exposure data at 29 CFR
1910.1020(d)(ii), an employer must keep any exposure data for at least
30 years.  EPA also takes comment on whether this requirement should be
incorporated in EPA’s rule, instead of the 3-year period.  

 5.   The Information Collected - Agency Activities, Collection
Methodology and Information Management.

a)   Agency Activities

 EPA activities associated with this requirement are: 

- to respond to questions from end users about the sufficiency of their
records

- to view records during inspections

b)   Collection Methodology and Management (including discussion of the
items mentioned in OMB(s remarks in the 1994 approval of the original
ICR)

EPA does not collect the information.  However, EPA staff could
potentially view records during inspections of facilities or request
copies from specific end users.

    

c)   Small Entity Flexibility

Small entities may contract with their suppliers for assistance in
exposure monitoring.  In addition, EPA is taking comment on ways to
reduce the total amount of monitoring required, as described above in
section 3.c.

d)   Collection Schedule

As with any records kept at a facility to demonstrate compliance, Agency
collection is on an (as needed( basis.  End users would need to update
their records every three months.

6.    Estimating the Burden and Cost of Collection

a)    Estimating Respondent Burden

b)    Estimating Respondent Costs

Table 6A/B presents estimates of annual respondent burden hours and
costs for each of the respondent activities described in section
4(b)(ii), with explanations of the assumptions made in each table.

Exhibit 6A/B: Annual Respondent Burden and Cost (1)

The following table shows estimates of respondent burden hours and
costs.  They are based on the following assumptions:

-Users will purchase exposure monitoring badges and have them analyzed
at $48 each and will require two badges for each worker using n-propyl
bromide during each monitoring event.

-We estimate as many as 3410 companies in the U.S. using n-propyl
bromide in the end uses addressed in the proposed regulation.  Up to
35,000 exposed workers would need to be monitored for exposure.  On
average, there are 10 workers to be monitored per respondent. 

-Based on current exposure data, we expect that as many as 30,000
workers will need to be monitored every six months.  Although we expect
as many as 3,500 workers to be at facilities that qualify for relief
from periodic monitoring, at some portion of facilities, there may be an
event resulting in an increase in exposure levels that requires new
monitoring.  To account for this possibility in a manner that does not
underestimate costs, we assume that up to 35,000 workers need to be
monitored once per year.

-Users will need to scan exposure monitoring results to see if they are
below the  exposure limit.  We estimate this will require ten minutes of
technical or managerial time for each worker using nPB once every
monitoring event, with an average of 1.9 monitoring events per year per
worker.  This equates to an average of 19 minutes per worker per year
and an average of 3.2 hours per year per respondent.

-End users will need to file the records.  We estimate this will require
two minutes of clerical time for each facility for each monitoring event
and worker, with an average of 38 minutes per year per respondent.  

- Labor costs representing an average hourly rate of pay, including
overhead and benefits, for a private company for labor that would be
classified as (technical( time at $60.00/hr and (clerical( time at
$20.00/hr.

- There is no start-up cost associated with this requirement.

-The annual operating and maintenance cost associated with this
recordkeeping requirement is based upon the above-mentioned labor costs
and the costs of monitoring badges and analysis.

	Table 6A/B: Annual Respondent Burden and Cost

Information Collection Activity	

A

Resp.

Hours per

Year	

B

Labor 

Cost (A)@ $60/

hr, B)@ $20/hr)

per Year

	

C

Annua-lized

Start-up

Cost 	D

Operating & Maintenance (O&M) Costs per respondent (avg of 38.6 badges
@$48 each per year)	

E

No. of

Resp	

F

Tot.

Hrs.

per

Year

(A*E)	

F

Total Annual-ized Cost per Year

(C*E)	

G

Total 

Labor

Cost

per

Year

(B*E)	H

Total O&M Costs per Year

(D*E)



Recordkeeping requirement	

	

	





	

	

	



	

A) Collect and review exposure data 	3.2	$193.14 	$0 	$1,854.12 	3410
10,975	$0 	$658,600 	$6,323,000 



B) File records	0.6	  $12.88 	$0 	0	3410	  2,195	$0 	$ 43,900 	$0 



                             Subtotals	3.9	$206.02 	$0 	$1,854.12 	3410
13,170	$0 	$702,500 	$6,323,000 



c)    Estimating Agency Burden and Costs

Exhibit 6C-1:  Annual Agency Burden and Costs

The following table shows estimates of EPA burden hours and costs for
the activities listed in section 5 above.  In making these estimates,
EPA made the following assumptions:

- The number of occurrences assumes that up to 1% of end users will have
sufficient questions about the recordkeeping requirement that they will
ask EPA for assistance.

- The number of hours per answer from EPA is 0.20, or 12 minutes.

- Labor cost is based on the annual 2005 salary for a GS 10/ Step 7
employee ($57,309), which is divided by 2,080 hours, the number of hours
in a federal work year  (resulting in an hourly rate of $27.55), then
multiplied by 1.6, the standard government benefits multiplication
factor (resulting in a final hourly rate of $44.08.)  

-Agency activities such as inspections and enforcement are beyond the
scope of this ICR.

Exhibit 6C-1:  Annual Agency Burden and Costs

Agency Activity	

No. of Occur-rences	

No. of Hours per Occur-rence	

Total No. of Hours per Year	

Labor Cost (@ $44.08/hr) per Year	

Cost of Contract Services per Year	

Total Cost per Year



Answer questions re: recordkeeping requirement	

    34	

   0.2	

   6.8	

$   300	

   n/a	

$  300 



              Totals	

    34	

   0.2	

   6.8	

$   300	

   n/a	

$   300



d)    Estimating the Respondent Universe and Total Burden and Costs  

See Table 6A/B in section 6(a) and (b) for these estimates.

e)    Bottom Line Burden Hours and Cost Tables

Exhibit 6E-1: Total Estimated Respondent Burden and Cost Summary

Information Collection Activity	

No. of Resp-ondents per Year	

No. of Activities per Year 	

Total Hours per Year	

Total Labor Cost per Year	

Total Annua-lized Start-up Costs	

Total Annua-lized O&M Costs	

Total Annua-

lized Costs





Total:  Recordkeeping for Use Condition	

Maximum of 3410	9,860	13,170	$702,500	$0	$6,323,000	$7,025,000



These numbers are from the subtotals of Table 6 A/B, and are used to
complete items 13 and 14 in Form 83-1.  Table 6E-1 counts two activities
for each collection of exposure data from each worker.

Exhibit 6E-2: Total Estimated Agency Burden and Cost Summary

Agency Activity	

No. of Respondents	

No. of Activities	

Total Hours per Year 	

Total Annual Labor Cost



Answer Questions Re: Recordkeeping Requirement	

3410	

34	

6.8	

$   300



                             Totals	

3410	

34	

6.8	

$   300



The total annual burden would remain the same from year to year.

f)    Reasons for Change in Burden

The total number of burden hours requested for this information
collection has increased from zero to 13,170 hours because of the new
program requirement. 

g)    Burden Statement

Exhibit 6A/B presents the average annual respondent burden for each
company subject to the new SNAP record-keeping requirement for use of
n-propyl bromide. 

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; 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.  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 numbers for EPA(s regulations are listed in 40 CFR Part
9 and 48 CFR Chapter 15.

Appendices

A-   Text of proposed SNAP regulation on n-propyl bromide      

B-   Text of Section 612 of the Clean Air Act as amended in 1990

C-   Text of SNAP Regulations, 40 CFR Part 82, Subpart G 

 PAGE  10 

